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

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Healthcare Provider Update: Healthcare Provider for Pacific Gas & Electric The primary healthcare provider for employees of Pacific Gas and Electric (PG&E) is often covered under large insurance carriers that offer comprehensive plans, including offerings from Blue Cross Blue Shield and UnitedHealthcare; the exact provider may vary depending on the employee's specific plan and regional options available. Projected Healthcare Cost Increases in 2026 As we look ahead to 2026, healthcare costs are anticipated to rise significantly due to a combination of factors. Insurers are reporting average premium increases that could exceed 20%, driven largely by ongoing inflation in healthcare services and the potential expiration of enhanced subsidies provided under the Affordable Care Act. This perfect storm of rising medical costs and diminished financial support could shock many consumers, with estimates suggesting that out-of-pocket premiums might surge by as much as 75% for individuals reliant on marketplace plans. As such, both employees and employers within PG&E should prepare for heightened expenses, taking proactive steps now to mitigate potential financial impacts. Click here to learn more

'With mandatory Roth catch-up contributions beginning in 2026 for higher earners, PG&E 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, PG&E 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 PG&E 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 PG&E 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 PG&E 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 PG&E 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 PG&E 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/

With the current political climate we are in it is important to keep up with current news and remain knowledgeable about your benefits.
PG&E offers two types of pension plans: the Final Pay Pension for employees hired before 2013 and the Cash Balance Pension for those hired after 2012. The Cash Balance Pension Plan credits a percentage of the employee's salary annually to an account that grows with interest. Additionally, PG&E contributes to a 401(k) plan with matching contributions, enhancing the retirement savings of its employees.
Wildfire Mitigation and Safety: PG&E is implementing a comprehensive wildfire mitigation plan, which includes laying off about 2,500 employees to improve operational efficiency (Source: Wall Street Journal). Strategic Focus: The company is focusing on grid safety and reliability. Financial Performance: PG&E reported a 7% increase in net income for Q2 2023, reflecting the success of its safety initiatives (Source: PG&E).
PG&E offers RSUs that vest over time, providing shares upon vesting. Stock options are also available, allowing employees to purchase shares at a fixed price.
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For more information you can reach the plan administrator for PG&E at p.o. box 5546 Concord, CA 94524; or by calling them at 925-349-2517.

https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/news-and-outreach/documents/pao/pphs/2022/fact-sheet--pge-ty-2023-grc-revised-on-april-5-2022.pdf - Page 5, https://docs.cpuc.ca.gov/PublishedDocs/SupDoc/A2106021/4046/403094527.pdf - Page 12, https://www.pge.com/documents/retirement-plan-2022.pdf - Page 15, https://www.pge.com/documents/retirement-plan-2023.pdf - Page 8, https://www.pge.com/documents/retirement-plan-2024.pdf - Page 22, https://www.pge.com/documents/401k-plan-2022.pdf - Page 28, https://www.pge.com/documents/401k-plan-2023.pdf - Page 20, https://www.pge.com/documents/401k-plan-2024.pdf - Page 14, https://www.pge.com/documents/rsu-plan-2022.pdf - Page 17, https://www.pge.com/documents/rsu-plan-2023.pdf - Page 23

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