Preparing for the Roth catch-up contribution mandate — Part 5

Over the past few articles, we’ve discussed the decisions that plan sponsors must make when implementing the Roth catch-up contribution mandate to identify high-income participants subject to the mandate,^[1] ensure that such high-income participants make catch-up contribution elections on a Roth basis,^[2] and correct any administrative failures that occur.^[3]

Once these decisions have been made, plan sponsors will need to develop a communication strategy. Since the rules go into effect on January 1, 2026, sponsors should begin communicating as soon as possible (if they have not started already) and consider using a phased and multi-channel approach tailored to their particular workforce. For example:

• An initial email or notice (separate from other year-end communications) might be sent to ensure that participants are aware of the changes that will go into effect on January 1, 2026, and how the new rules will work in their plan.
• This might be followed by FAQs, webinars and the like providing educational information about Roth contributions, such as: (1) contributions are after-tax, so pay after taxes will be lower for participants accustomed to making catch-up contributions on a pre-tax basis; and (2) Roth contributions provide other tax benefits that may be beneficial from a retirement savings strategy perspective — e.g., they grow tax-free, can generally be withdrawn tax-free in retirement and will reduce required minimum distributions. Sponsors might also consider providing modeling tools or examples of participants at various pay levels and career stages.
• Targeted communications may also be sent to participants subject to the mandate to ensure they understand their catch-up contribution options. These communications should be delivered with adequate time for affected participants to make changes to their deferral elections. As discussed in our prior articles, if a deemed Roth catch-up election is used, affected participants must have an “effective opportunity” to make a different election (e.g., to opt out of catch-up contributions and, in some cases, to change the deemed Roth catch-up election back to pre-tax) and should receive notice of the opportunity to make a different election prior to the time that the deemed election goes into effect. If an affirmative election approach is used, affected participants may have their existing catch-up contribution elections “zeroed out” and should be notified before that happens about how to make an affirmative Roth election to restart their catch-up contributions. These communications might also encourage affected participants to consult with their tax or financial advisors before updating deferral elections.

There is no one “right” approach, but the communication strategy should be designed to ensure that participants have a clear understanding of the changes and a sufficient opportunity to act.

If you need help developing a communication strategy, your WTW team and our Roth catch-up contribution experts are available to help.

Footnotes

1. See Part 2, “Identifying high-income earners subject to the mandate,” Insider, November 2025 Return to article undo
2. See Part 4, “To deem or not to deem,” Insider, November 2025 Return to article undo
3. See Part 3, “Correcting Roth catch-up contribution mistakes,” Insider, November 2025 Return to article undo

Authors

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Gary Chase

Director, RIC Technical Services, LifeSight U.S. Head of Compliance

email Email phone +1 212 309 3802

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Stephen Douglas

Senior Director, Retirement and Executive Compensation

email Email phone +1 203 326 6315

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William “Bill” Kalten

Senior Director, Retirement and Executive Compensation

email Email phone +1 203 326 4625

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