[UCRDBR] SECURE 2.0 Act Clarification: Processing of Pretax and Roth Contributions Under 2026 Catch-Up Contribution Rules

Fri Oct 9 08:42:54 PDT 2026

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October 9, 2026
To:
Department Benefits Representatives (DBRs)
From:
Central HR Benefits Office on behalf of UC Office of the President
Re:
SECURE 2.0 Act Clarification: Processing of Pretax and Roth Contributions Under 2026 Catch-Up Contribution Rules

DBRs, please share this information via your internal listserv.  Please do not reply to this email.  Please send a separate email with questions to benefits at ucr.edu<mailto:benefits at ucr.edu>.

UCOP provides additional clarification regarding the HRB issued on December 11, 2025 (below), in response to questions received from locations and employees concerning the application of SECURE 2.0 catch-up contribution rules. It explains how pretax and Roth contribution elections are applied under the 2026 contribution limits for UC's 403(b) and 457(b) Plans, including the SECURE 2.0 requirements for certain age-50+ catch-up contributions.
The SECURE 2.0 Act made several changes to retirement plan rules, including a requirement that certain employees whose prior-year earnings exceed a specified earnings threshold and are age-50+, catch-up contributions are required to be made on a Roth basis.
UC applies catch-up contributions for employees subject to the SECURE 2.0 high-earner requirements as follows:
1. Employee elects pretax contributions only:
Contributions are applied on a pretax basis up to the annual IRS limit of $24,500 in each plan. Any catch-up contributions are required to be applied as Roth contributions, up to the annual IRS limit of $32,500 per plan.
2. Employee elects Roth contributions only:
Contributions are applied on a Roth basis up to the annual IRS limit of $24,500 in each plan. Any catch-up contributions are required to be applied as Roth contributions, up to the annual IRS limit of $32,500 per plan.
3. Employee elects both pretax and Roth contributions:
Contributions are applied on a pretax and Roth basis up to the annual IRS limit of $24,500 in each plan. This limit applies to the combined total of both contribution types rather than separately to each. As a result, an employee may reach the $24,500 limit before contributing $24,500 on a pretax basis. Any remaining contributions are then applied as Roth contributions, up to the annual IRS limit of $32,500 per plan.
UCOP recognize that the original communication could have provided greater clarity regarding how these contributions are administered. To address this, employee communications and UC's SECURE 2.0 resources on myUCretirement.com are being updated to further explain how an employee's contribution elections affect the treatment of catch-up contributions.
Employees seeking additional information about SECURE 2.0 may review IRS guidance regarding catch-up contribution requirements for higher-earning participants, as well as the retirement resources available on myUCretirement.com.
December 11, 2025 Communication:
Beginning January 1, 2026, several significant updates to annual contribution limits and catch-up rules for the UC 403(b) and 457(b) Plans will take effect. These updates will apply to employees who will be age 50 or older in 2026 with 2025 earnings that exceed $150,000.  Some of the changes may directly affect the rules for whether their catch-up contributions are pretax (with taxes paid when they withdraw funds) or Roth (with after-tax contributions now and potential tax-free withdrawals in retirement).

Key Changes Effective January 1, 2026-Employee Action May Be Required

  1.  New 2026 contribution limits
Eligible participants may contribute up to $24,500 to each plan (pretax and/or Roth), plus an $8,000 age-50+ catch-up to each plan (see section 2 below for more information), for a total of $32,500 per plan or $65,000 total (standard and age-50+ catch-up combined) across both plans.  Employees' 2025 contribution amounts will automatically carry over into 2026.
  2.  Required Roth catch-up contributions for high earners
Under SECURE 2.0, if a participant's 2025 Social Security (FICA) wages exceed $150,000, all age-50+ catch-up contributions made in 2026 must be Roth.  Regular contributions up to $24,500 may still be pretax, Roth or a combination, based on the employee's current election with Fidelity.  Catch-up contributions will be treated as Roth even if the employee did not designate them as Roth with Fidelity.
Here are some examples:

Employees' Election with Fidelity
How 2026 Contributions Will Be Treated
All pretax
First $24,500 is pretax; amounts over $24,500 are Roth.
All Roth
All contributions are Roth.
Mix of pretax and Roth
Mix applies up to $24,500; amounts above $24,500 are Roth until the Roth catch-up limit is reached. Then, pretax and Roth deductions resume as originally elected.

  1.  New "Super Catch-Up" for participants ages 60-63
Participants who will be ages 60-63 in 2026 may contribute up to $11,250 in catch-up contributions per plan. This allows up to $35,750 per plan, or as much as $71,500 across both plans.  The enhanced "super catch-up" limit for ages 60-63 replaces the standard $8,000 catch-up noted above and is subject to the same SECURE 2.0 Roth catch-up requirement for high earners.
High earning employees who prefer to manage their pretax vs. Roth contributions more intentionally in 2026 may consider splitting contributions across both 403(b) and 457(b) plans; details are included in this participant communication<https://fwc.widen.net/s/hcv255dczc/secure-2.0-email>.

Next Steps for Employees

Participants are encouraged to:

  *   Schedule a 1:1 consultation<https://digital.fidelity.com/prgw/digital/wos/one-on-one?planSponsorId=700003> or call 1-800-558-9182 (no appointment needed) to speak with a UC-dedicated Fidelity Retirement Planner about their 2026 contribution strategy, the impact of required Roth catch-ups, modifying their elections, planning for retirement and more.  Employees can learn more about the UC 403(b) and 457(b) Plans on myUCretirement.com<https://myucretirement.com/>.
  *   Review their January 2026 contribution elections in NetBenefits<https://nb.fidelity.com/static/mybenefits/netbenefitslogin/#/login>. Deferral elections can be changed at any time on NetBenefits<https://nb.fidelity.com/static/mybenefits/netbenefitslogin/#/login> or by calling 1-800-558-9182.  However, to help ensure that their elections take effect when they intend, employees should submit their election changes according to the pay frequency schedule on the UCPath 2026 payroll calendar<https://ucop.edu/ucpath-center/_files/mypath/calendar/rsp-enrollment-change-dates-2026.pdf> or the UCPath 2026 payroll calendar for LBNL employees<https://ucop.edu/ucpath-center/_files/mypath/calendar/lbnl-rsp-enrollment-change-dates-2026.pdf>.
If no changes are made, age-50 catch-up contributions for high earners will automatically be processed as Roth-as required by SECURE 2.0.
Communications & Resources
A detailed email announcement<https://fwc.widen.net/s/hcv255dczc/secure-2.0-email> outlining these upcoming 2026 changes will also be issued to active plan participants who will be age 50 or older in 2026 and whose 2025 earnings exceed $150,000.  The UCPath Center also plans to distribute a similar update.
Employees can learn more about the 2026 IRS contribution limits on myUCretirement.com<https://www.myucretirement.com/resources/articles/0085>.  Additional communications about the new limits will be sent to active participants in January 2026.

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