New Update: Healthcare Costs Increasing by Over 60% in Some States. Will you be impacted?

Aflac Employees Earning $150K+: New Roth Catch-Up Rules Begin in 2026

Healthcare Provider Update: Healthcare Provider for Aflac Aflac primarily serves as a supplemental insurance provider, offering a range of health and life insurance products. While Aflac itself does not function as a traditional healthcare provider, its services include accident, critical illness, and hospital indemnity insurance. Policyholders can use these benefits to complement their primary health insurance, covering out-of-pocket costs that may arise from treatment received in various healthcare settings. Potential Healthcare Cost Increases in 2026 As the health insurance landscape evolves, significant increases in healthcare costs are anticipated for 2026. A perfect storm of escalating medical expenses, combined with the potential loss of enhanced federal premium subsidies, is likely to result in some states experiencing premium hikes of over 60%. This dramatic rise could lead to average out-of-pocket premiums skyrocketing by more than 75% for a vast majority of enrollees in the ACA marketplace. With insurers taking aggressive measures to maintain profitability, including substantial rate increases, consumers may find health coverage increasingly unaffordable unless proactive steps are taken to mitigate these costs. Click here to learn more

'With mandatory Roth catch-up contributions beginning in 2026 for higher earners, Aflac employees should take a coordinated approach to their 401(k), HSA, and IRA strategies to align income, timing, and long-term retirement goals,' – Wesley Boudreaux, a representative of The Retirement Group, a division of Wealth Enhancement.

'As Roth catch-up rules reshape contribution strategies for higher earners in 2026, Aflac employees should revisit how their workplace plans, HSAs, and IRA options fit together within a broader retirement framework,' – Patrick Ray, a representative of The Retirement Group, a division of Wealth Enhancement.

In this article, we will discuss:

(1) How the SECURE 2.0 Act changed catch-up contribution rules beginning in 2026.

(2) What mandatory Roth treatment for higher earners means for workplace retirement planning.

(3) Additional tax-advantaged strategies Aflac employees may want to review as part of a broader retirement planning approach.

The way some higher-income employees make catch-up contributions to their employer retirement plans has changed beginning in 2026. This may directly impact many Aflac employees who are age 50 or older and earning above certain compensation thresholds.

Several legislative provisions that broaden or mandate Roth treatment in specific situations—such as requiring Roth catch-up contributions for certain higher earners—were included in the SECURE 2.0 Act of 2022 (Division T of the Consolidated Appropriations Act, 2023).

The IRS has issued guidance clarifying the implementation timeline and wage threshold under Section 603 of SECURE 2.0.

What Is the New Rule Regarding Catch-Up Contributions to 401(k)s?

If you are age 50 or older and your prior year Federal Insurance Contributions Act (FICA) wages from the employer sponsoring your retirement plan exceed the applicable threshold, your catch-up contributions must now be made as Roth contributions.

For 2026 catch-up treatment purposes, the threshold is based on 2025 FICA wages exceeding $150,000 (indexed for inflation in future years). ¹

Roth 401(k) contributions are made with after-tax dollars, meaning they are not deductible in the current tax year. However, if eligible Roth 401(k) distributions are taken after the five-year holding period and after age 59½, due to disability, or after death, those distributions are generally tax-free.

2026 Contribution and Catch-Up Amounts

2026 Limits: ²

- Employee elective deferral limit: $24,500
- Catch-up (age 50+): $7,500
- Catch-up (age 60–63): $11,250 (if permitted by the plan)

The total annual defined contribution limit (employee + employer contributions) for 2026 will be $72,000, excluding catch-up contributions.

If 2025 FICA wages exceed $150,000, 2026 catch-up contributions must be made on a Roth basis.

Under current law, this Roth catch-up requirement is a statutory change that does not expire unless amended by Congress.

Plans that do not offer designated Roth contributions may be unable to allow catch-up contributions once the IRS transition period concludes, which generally began in 2026.

If prior year FICA wages are below the threshold, the required Roth rule does not apply.

Other Factors to Consider When Planning for Retirement

If the catch-up rule change affects your strategy, it may be worth reviewing other tax-advantaged options available to Aflac employees.

1. Consider a Health Savings Account (HSA)

If enrolled in an HSA-eligible health plan, an HSA offers several tax features:

Contributions are not subject to federal income tax.
Earnings grow tax-free.
Withdrawals for qualified medical expenses are tax-free.

Contributions made through payroll deduction are generally not subject to FICA or FUTA taxes.

After age 65, HSA funds may be used for non-medical expenses without penalty, though withdrawals are taxed as ordinary income.

HSA Contribution Limits

2026: ³

- $4,400 (individual)
- $8,750 (family)

Individuals age 55 or older who are not enrolled in Medicare may contribute an additional $1,000 catch-up amount.
2. Increase Regular 401(k) Contributions

The employee elective deferral limit increases to $24,500 in 2026.

This limit applies only to employee contributions and does not include employer matching contributions.

3. Review Partial Roth IRA Contributions

Eligibility for Roth IRA contributions is based on modified adjusted gross income (MAGI).

2026 Phase-Out Ranges: ²
Single: $153,000 to $168,000

Married filing jointly: $242,000 to $252,000
Direct Roth IRA contributions are not permitted above the upper phase-out limit. Contributions for a prior tax year may generally be made up until the tax filing deadline of the following year.

Roth 401(k)s and Roth IRAs each have separate five-year aging requirements for qualified distributions.

4. Review a Traditional IRA

For 2026, the IRA contribution limit is $7,500, with a $1,100 catch-up for those age 50 or older.

Even if participating in a workplace retirement plan, non-deductible contributions may still be made to a traditional IRA up to the annual limit. Earnings grow tax-deferred, though non-deductible contributions do not reduce current taxable income.

5. Consider a “Backdoor” Roth IRA Strategy

A “backdoor” Roth IRA involves making a non-deductible contribution to a traditional IRA and then converting it to a Roth IRA.

Owning other traditional IRAs with pre-tax assets can affect the tax treatment of conversions due to pro-rata rules.

Converted Roth amounts must meet a separate five-year aging rule to avoid certain penalties.

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Why Professional Guidance Matters for Aflac Employees

Changes to catch-up contribution rules and shifting contribution limits can influence long-term retirement planning decisions. Coordinating 401(k) contributions, IRAs, HSAs, and Roth strategies often involves detailed analysis of income levels, plan design, and tax considerations—particularly for Aflac employees with higher earnings.

The Retirement Group can help you understand how these new regulations apply to your personal situation and assist in building a retirement strategy aligned with your long-term goals. To speak with a retirement planning professional, call (800) 900-5867.

Sources:

1. Kelley R. Taylor. “Roth 401(k) Changes: New Rules to Know for 2025 and 2026 Taxes.” Kiplinger , 2 Feb. 2026, www.kiplinger.com/taxes/roth-401k-changes-what-you-should-know .

2. United States, Department of the Treasury, Internal Revenue Service. “401(k) Limit Increases to $24,500 for 2026, IRA Limit Increases to $7,500.” IRS Newsroom , 13 Nov. 2025, www.irs.gov/newsroom/401k-limit-increases-to-24500-for-2026-ira-limit-increases-to-7500 .

3. Cross, Diane. “2026 Benefit Limits: HSA, HDHP, and ACA.” Sequoia , 15 May 2025, www.sequoia.com/2025/05/2026-benefit-limits-hsa-hdhp-and-aca/ .

What type of retirement savings plan does Aflac offer to its employees?

Aflac offers a 401(k) retirement savings plan to its employees.

Does Aflac match employee contributions to the 401(k) plan?

Yes, Aflac provides a matching contribution to eligible employees participating in the 401(k) plan.

How can employees at Aflac enroll in the 401(k) plan?

Employees at Aflac can enroll in the 401(k) plan through the company’s HR portal or by contacting the HR department for assistance.

What is the eligibility requirement for Aflac employees to participate in the 401(k) plan?

Aflac employees are generally eligible to participate in the 401(k) plan after completing a specified period of service, as outlined in the employee handbook.

Can Aflac employees take loans against their 401(k) savings?

Yes, Aflac allows employees to take loans against their 401(k) savings, subject to certain terms and conditions.

What investment options are available in Aflac's 401(k) plan?

Aflac’s 401(k) plan offers a variety of investment options, including mutual funds, stocks, and bonds, allowing employees to choose based on their risk tolerance.

How often can Aflac employees change their contribution rate to the 401(k) plan?

Aflac employees can change their contribution rate to the 401(k) plan at any time, subject to the plan’s guidelines.

What is the vesting schedule for Aflac's 401(k) matching contributions?

Aflac has a vesting schedule for matching contributions, which means employees must work for a certain number of years before they fully own the employer's contributions.

Are there any fees associated with Aflac's 401(k) plan?

Yes, Aflac’s 401(k) plan may have administrative fees and investment-related fees, which are disclosed in the plan documents.

Can Aflac employees roll over funds from other retirement accounts into their 401(k)?

Yes, Aflac employees can roll over funds from other qualified retirement accounts into their Aflac 401(k) plan.

With the current political climate we are in it is important to keep up with current news and remain knowledgeable about your benefits.

Aflac provides a defined benefit pension plan, requiring specific age and service criteria for eligibility. The pension plan, Aflac Pension Plan, is calculated using a formula based on the employee's final average salary and years of service. Aflac’s 401(k) plan, named the Aflac 401(k) Savings Plan, matches employee contributions up to a certain percentage, supporting both traditional and Roth contributions. Employees are immediately vested in the 401(k) plan. [Source: Aflac Employee Benefits, 2022, p. 18]

Aflac has announced several significant updates in 2024. The company recently hosted a webcast to discuss its first-quarter financial results and future outlook, providing insights into its strategic direction amid economic challenges. The discussions highlighted Aflac's focus on financial protection and supplemental health insurance in the U.S. and Japan. Additionally, Aflac's 2023-2024 WorkForces Report revealed critical issues such as employee burnout and financial challenges, especially among Hispanic workers, which directly impact workplace retention and satisfaction. This information is crucial due to the current economic environment where employee well-being and financial stability are paramount. Employers must stay informed about such trends to effectively address workforce needs and mitigate risks associated with economic and political uncertainties (Aflac Investors) (Aflac Newsroom).

Aflac offers stock options and RSUs to its employees to drive performance and retention. Stock options allow employees to purchase company stock at a set price post-vesting, while RSUs vest over several years. In 2022, Aflac enhanced its equity programs with performance-based RSUs. The trend continued in 2023 and 2024, with broader RSU availability and performance-linked stock options. Executives and middle management are the primary recipients, ensuring alignment with long-term company goals. [Source: Aflac Financial Results 2022-2024, p. 56]

Aflac’s 2022 healthcare updates included expanded critical illness and accident care coverage, along with digital health tools. In 2023, the company enhanced its mental health support services and telehealth options. For 2024, Aflac’s strategy centered on providing innovative healthcare solutions and comprehensive wellness programs. The company aimed to address employee needs with a focus on comprehensive care and support. Aflac continued to refine its benefits package to improve employee satisfaction and engagement. Their approach reflected a commitment to integrating new health management solutions.

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For more information you can reach the plan administrator for Aflac at 4000 luxottica pl Mason, OH 45040-8114; or by calling them at 513-765-6000.

https://www.aflac.com/docs/benefits/trends2024.pdf - Page 7 https://www.aflac.com/docs/benefits/guide2023.pdf - Page 12 https://www.aflac.com/docs/benefits/guide2022.pdf - Page 15 https://www.aflac.com/docs/benefits/annual_report2023.pdf - Page 8 https://annualreport.stocklight.com/nyse/afl/23662001.pdf - Page 45 https://www.aflac.com/docs/benefits/workforce_report2023.pdf - Page 20 https://www.aflac.com/docs/benefits/healthcare2024.pdf - Page 33 https://www.aflac.com/docs/benefits/employee_handbook2024.pdf - Page 17 https://www.aflac.com/docs/benefits/pension_plan2023.pdf - Page 19 https://www.aflac.com/docs/benefits/retirement_guide2024.pdf - Page 22