Roth Catch-Up Requirement

SECURE 2.0: 401(k) Catch-Up Contributions Starting January 1, 2026

LATEST UPDATE:

UPDATE DECEMBER 11, 2025:  As updates from the SECURE 2.0 Act and the IRS will soon go into effect, we want to ensure you have clear, timely information so you can make informed decisions and plan ahead with confidence. These changes will impact 401(k) Elective Deferrals and Catch-Up contributions for the Forvis Mazars Plan beginning on January 1, 2026.

Beginning January 1, 2026, employees who will be age 50 (or turning 50 in 2026) or older and who earn more than $150,000 FICA wages in 2025 from Forvis Mazars will be required to make 401(k) Catch-Up contributions as Roth instead of Pre-Tax contributions. Additionally, Pre-Tax and Roth elective 401(k) deferrals will be taken out of your paycheck until you reach the 2026 elective deferral limit of $24,500, and only then will any elected Catch-Up contributions begin.

How will this Impact my 401(k) Withholdings?

  • All Pre-Tax and/or Roth elective 401(k) deferrals will continue until impacted employees reach the 2026 elective deferral limit of $24,500. 
  • Catch-Up contributions will not begin until that limit is reached and only if you have affirmatively elected them in your Schwab account.
  • This is a shift from past years where multiple 401(k) deferrals could be withheld simultaneously.

Action Required:

For employees aged 50 or older, or who will be turning 50 in 2026, please take a moment to review your final 2025 paystub to confirm your year-to-date OASDI taxable wages (FICA wages) and then log in to your Charles Schwab account after January 1, 2026 at workplace.schwab.com to:

  • Review your current elective deferrals and if applicable, elect your 2026 Catch-Up contribution. Contribution changes must be made through your Schwab account after January 1, 2026.  Please note it can take 1-3 pay periods for the changes to go into effect.

Resources to Help you Decide: 

Model different contribution rates and timing to see the impact on your deferrals. This template is used for estimating potential 401(k) withholding only and should not be used as tax advice. We ask team members to consult with their own tax or personal advisor.

Disclaimer: This file will not adjust your elective deferrals as you must affirmatively elect your deferrals on your Charles Schwab account. Actual amounts may vary by team members.

 

UPDATE NOVEMBER 17, 2025: The IRS recently issued Notice 2025-67, providing 2026 retirement plan and IRS limits. These updates  can be found here (insert anchor link to the dropdown where we posted the new limits). The notice also confirmed the 2025 FICA wage threshold for Roth Catch-Up contributions increased from $145,000 to $150,000. 

What this means: Employees aged 50 or older in 2026, who earned more than $150,000 in FICA wages from Forvis Mazars in 2025, will be required to make their Catch-Up contributions as Roth, effective January 1, 2026.

As previously communicated, changes to the Forvis Mazars, LLP Employees’ Savings Plan will take effect January 1, 2026, due to SECURE 2.0 legislation. Employees aged 50 or older in 2026, who earned more than $145,000 in FICA wages from Forvis Mazars in 2025, will be required to make Roth catch-up contributions instead of Pre-Tax.

If impacted, Schwab will automatically set your Pre-Tax catch-up contribution rate to 0% and prevent Pre-Tax catch-up elections for the remainder of 2026. If you would like to make catch-up contributions, you must affirmatively elect Roth catch-up by logging into your Schwab account or calling Schwab Retirement Plan Services.

Next Steps

Starting in November and continuing through 2026, Schwab will send communications to employees who will be age 50 or older. Please review these messages and continue to check this page for more information.

For additional questions, please contact Schwab Retirement Plan Services at 800-724-7526, or you can submit a case in Workday by selecting the “Create Case” icon on the homepage.

If you are aged 50 or order by December 31 of each year, the IRS lets you contribute extra money to your 401(k), called a ‘catch-up contribution’. It is used to help employees save more as you get closer to retirement.

Starting January 1, 2026, employees who are age 50 or older by the end of the 2026 calendar year, and who earned more than $150,000 in FICA wages from Forvis Mazars in 2025, will be required to make catch-up contributions on a Roth (after-tax) basis. This means those contributions will be taxed upfront, but grow tax-free for retirement*.

*Individuals must have the Roth 401(k) account established for five years and be over the age of 59½ for tax-free withdrawals.

No. The rule only applies to catch-up contributions. Your regular elective deferrals can still be made on a Pre-Tax or Roth basis, depending on your deferral elections in Schwab.

Generally, no. The Roth catch-up requirement does not apply to partners, as they do not receive W-2 wages.

However, newly promoted partners may be impacted if their FICA wages exceed the threshold during the calendar year in which they transition to partner.

After the December 31, 2025 payroll closes, Forvis Mazars will report to Schwab any 2025 FICA wages that exceed the threshold. Schwab will send direct communication to impacted individuals, confirming they are subject to the Roth catch-up requirement beginning in 2026.

You may review the provided scenarios to determine whether you are affected by this change.

If you would like to update your contributions, you can follow these steps below. You can also call Schwab Participant Plan Services at 1-800-724-7526 for any assistance. Please note it can take 1-3 pay periods for the changes to go into effect.

  1. Log into your Schwab 401(k) account by visiting https://workplace.schwab.com/
  2. On the Manage Account tab, click change contribution.
  3. Make affirmative election to be withheld on a per payroll basis for both your base pay and/or catch-up deferrals.
  4. Opt in or out of annual saving increase.
  5. Make sure to click save or confirm and save a copy for your records.

The Compensation & Retirement Plan Team are working alongside Charles Schwab to implement this new provision. We encourage you to regulary review the Retirement page on the Benefits Resource Center as we will post additional updates as soon as they are available.  Below are links to Roth 401(k) education available from Schwab.

What Will Happen if I am Impacted?

If impacted, Schwab will automatically set your Pre-Tax catch-up contribution rate to 0% and prevent Pre-Tax catch-up elections for the remainder of 2026. If you would like to make catch-up contributions, you must affirmatively elect Roth catch-up by logging into your Schwab account or calling Schwab Retirement Plan Services.

Scenario 1: Age 49 or under as of December 31, 2026
Employee Type Eligible for Catch-Up Contributions? Does the Roth Catch-Up Rule Apply? Type of contributions that can be made
New hire in 2026 with no wages from Forvis Mazars in 2025, current or rehired employees No No Pre-Tax and Roth elective deferrals up to the IRS annual maximum. Not eligible for catch-up
Scenario 2: Age 50 - 59 as of December 31, 2026
Employee Type Eligible for Catch-Up Contributions? Does the Roth Catch-Up Rule Apply? Type of contributions that can be made
New hire in 2026 with no wages from Forvis Mazars in 2025 Yes No Catch-up contributions can be made as Pre-Tax and/or Roth
Current or Rehired employees Yes Review 2025 Forvis Mazars FICA wages FICA wages less than $150,000 in 2025: catch-up contributions can made as Pre-Tax and/or Roth

FICA wages greater than or equal to $150,000 in 2025: catch-up contributions must be made as Roth only
Scenario 3: Age 60-63 as of December 31, 2026

Separate from the Roth mandate, employees aged 60-63 in calendar year 2026 are permitted to increase their catch-up contribution to $11,250. These contributions must also be Roth if the employees 2025 FICA wages were $150,000 or more.
Employee Type Eligible for Catch-Up Contributions? Does the Roth Catch-Up Rule Apply? Type of contributions that can be made
New hire in 2026 with no wages from Forvis Mazars in 2025 Yes No Catch-up contributions can be made as Pre-Tax and/or Roth
Current or Rehired employees Yes Review 2025 Forvis Mazars FICA wages FICA wages less than $150,000 in 2025: catch-up contributions can made as Pre-Tax and/or Roth

FICA wages greater than or equal to $150,000 in 2025: catch-up contributions must be made as Roth only
Scenario 4: Age 64+ as of December 31, 2026
Employee Type Eligible for Catch-Up Contributions? Does the Roth Catch-Up Rule Apply? Type of contributions that can be made
New hire in 2026 with no wages from Forvis Mazars in 2025 Yes No Catch-up contributions can be made as Pre-Tax and/or Roth
Current or Rehired employees Yes Review 2025 Forvis Mazars FICA wages FICA wages less than $150,000 in 2025: catch-up contributions can made as Pre-Tax and/or Roth

FICA wages greater than or equal to $150,000 in 2025: catch-up contributions must be made as Roth only

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