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

'With mandatory Roth catch-up contributions beginning in 2026 for higher earners, Dow Incorporated 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, Dow Incorporated 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 Dow Incorporated 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 Dow Incorporated 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 Dow Incorporated 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 Dow Incorporated 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 Dow Incorporated 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/ .

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For more information you can reach the plan administrator for Dow Incorporated at 1919 torrance blvd Torrance, CA 90501; or by calling them at 900-999-1009.