An owner turns 60 in June 2026, has deferred $18,000 a year into a solo 401(k) for a decade, and assumes the catch-up is still $7,500 — the same number from age 50. Across town, a five-person agency launches its first 401(k) in January 2026, picks a 3% match, and assumes enrollment is voluntary as it always was for small plans. By year-end, the owner left $3,750 of tax-deferred capacity on the table that the statute made available only for four birthdays, and the agency receives a correction notice — every plan established after December 29, 2022 must auto-enroll at 3–10% and auto-escalate to at least 10% starting with the 2025 plan year, with only narrow exemptions. Both errors are correctable; both are avoidable by reading the calendar the SECURE 2.0 Act wrote into the Code.
The SECURE 2.0 Act of 2022 (Division T of the Consolidated Appropriations Act, 2023) stretched in-service retirement rules across three effective-date waves — 2023, 2024, and 2025-2026. By 2026 both of its small-business headlines apply at once: a new super catch-up window at ages 60–63 that raises the 50+ limit by 50%, and a new automatic enrollment and escalation mandate that covers nearly every 401(k) or 403(b) plan first established after December 29, 2022. This guide maps who gets the $11,250 super catch-up, how it stacks with the regular and Roth catch-up rules in 2026, what auto-enrollment requires a new plan to operate, and the payroll and bookkeeping steps that keep both from becoming a failed ADP/ACP test or a missed-deferral correction.
The Super Catch-Up — A Four-Year Window at $11,250
Who, when, and how much
Eligibility is age-on-the-last-day. You are eligible for the super catch-up in the calendar year you turn 60, 61, 62, or 63 on December 31 — not the plan year, not an anniversary. Turn 60 on December 15, 2026: eligible for all of 2026. Turn 64 on January 10, 2026: not eligible in 2026, even though you were 63 for ten days that year. The window is four calendar years, no extension — at 64 you fall back to the regular 50+ catch-up.
Dollar amount. SECURE 2.0 §109 defines the super catch-up as the greater of $10,000 (indexed) or 150% of the regular age-50 catch-up limit for that year. Indexed from 2025:
- 2025 official (Notice 2024-80): elective deferral limit $23,500; regular 50+ catch-up $7,500 (total $31,000 for 50+); super catch-up $11,250 (150% × $7,500), for a total of $34,750 for ages 60–63.
- 2026 projected (indexed, to be confirmed in Notice 2025-XX in October 2025): elective deferral ~$24,000–$24,500 and regular catch-up likely $7,500–$8,000 — super at 150% will be $11,250–$12,000 where the regular limit rises. Plan your 2026 budget on $11,250 as the floor the statute guarantees; the IRS notice in the fall will finalize the indexed figure — do not round up before the notice.
Where the regular catch-up is already indexed to inflation — as it was in 2023 — the super amount at 150% automatically tracks it. Congress indexed the $10,000 base separately starting in 2026, so the higher of the two controls.
Stacking rules. The super catch-up replaces, not adds to, the regular catch-up — you do not get $7,500 plus $11,250. The choice for a 62-year-old in 2026 is:
- Under 50: $23,500 (2025) / ~$24,000–$24,500 (2026 projection)
- 50–59 and 64+: $23,500 + $7,500 = $31,000 total
- 60–63: $23,500 + $11,250 = $34,750 total (or the 2026 indexed equivalents — e.g., ~$24,500 + ~$11,500 = ~$36,000)
A solo-owner couple where one spouse is 62 and the other is 59 illustrates the point — same business, same 401(k), two different caps in the same calendar year.
Why the window matters more than the math
The super catch-up is valuable precisely because many owners' peak deferral capacity coincides with peak earnings in the early 60s — mortgage paid, kids' expenses past, business at maturity. $3,750 of extra pre-tax (or Roth) capacity for four years is $15,000 of incremental deferral at today's rates; at 24% marginal, roughly $3,600 of federal tax deferred across the window before state, plus tax-deferred growth on the incremental dollars. Miss the four-year window and there is no catch-up to the catch-up.
Coordination with SIMPLE and governmental plans. SIMPLE IRAs have their own indexed limits (2025: $16,500 + $3,500 catch-up / $5,250 super at 150%), so a SIMPLE through a side employer is not interchangeable with a 401(k) super figure — do not apply the $11,250 to a SIMPLE.
The Roth Catch-Up Twist That Arrives With It
SECURE 2.0 §603 requires that catch-up contributions for higher-paid participants be Roth (after-tax, then tax-free earnings). Effective date was delayed twice — final IRS guidance (proposed and transitional) now pushes mandatory compliance to plan years beginning after December 31, 2025 — meaning 2026 is the first year it is enforced for calendar-year plans.
Who it affects in 2026:
- Wages > $145,000 in the prior calendar year (indexed to ~$150,000–$155,000 for 2026) — FICA wages from the employer sponsoring the plan — must have any catch-up (regular or super) as Roth. A 62-year-old earning $162,000 in 2025 who wants the $11,250 super in 2026 must make that $11,250 — and any other catch-up — as Roth deferrals inside the plan, assuming the plan offers Roth.
- Below the threshold, catch-up may be pre-tax or Roth at the participant's election.
What that means operationally: a plan that has not added a Roth contribution source by 2026 cannot accept catch-ups from high earners at all, and a payroll system that cannot tag Roth vs. pre-tax catch-up cannot correctly code the W-2 (Roth appears in Box 1). Sponsors who delayed the Roth amendment in 2023–2025 now have a hard gating item for every 60-plus high earner who wants the super.
The Auto-Enrollment Mandate — Every New Plan Since December 30, 2022
SECURE 2.0 §101 added Code §§ 414A and 414(d)-related regs: any 401(k) or 403(b) plan established after December 29, 2022 must include an eligible automatic contribution arrangement (EACA) beginning with plan years after December 31, 2024 — i.e., 2025 plan years, and therefore fully applicable in 2026.
What the mandate requires
- Initial automatic elective contribution: At least 3% and no more than 10% of compensation — set by the plan document.
- Automatic escalation: Increase by 1% per year until reaching at least 10% and no more than 15% — participant may elect out of escalation.
- Permissible withdrawal: Employees automatically enrolled may withdraw automatic contributions (plus earnings) within 90 days of the first automatic contribution — taxed in the year withdrawn, no 10% early-withdrawal penalty where the EACA rules are met.
- Investment default: Automatically enrolled dollars go to a qualified default investment alternative (QDIA) — typically a target-date fund — unless the participant directs otherwise.
Who must, and who need not
Covered: Every new 401(k) — including a solo 401(k) that adds an employee — and 403(b) plan whose plan was first established after 12/29/2022. The test is when the plan was established, not when the employer was formed. An LLC formed in 2019 that adopts its first 401(k) on March 1, 2024 is a covered new plan — mandatory EACA in 2025/2026.
Exempt (§414A(c)) — narrow:
- Businesses that have been in existence less than 3 years (3-year lookback from plan adoption)
- Employers normally employing 10 or fewer employees (preceding-year headcount)
- Church plans and governmental plans
- SIMPLE 401(k) arrangements (SIMPLE IRAs are a different regime)
- Plans adopted before 12/30/2022 are grandfathered for all future years — a 2021 plan that adds a feature in 2025 remains exempt; a spin-off plan from a grandfathered plan generally inherits the grandfather.
Most classic startup 401(k) adopters in 2026 — a 2015 LLC with 15 employees adopting its first plan in 2024 — are not exempt.
What "automatic" actually requires in the office
Auto-enrollment is not "we told them they could enroll." It is:
- Eligibility tracked and noticed. Every eligible employee (including part-time under the long-term part-time rules — see below) receives a notice 30–90 days before the first automatic contribution describing the default percentage, escalation schedule, QDIA, and opt-out/withdrawal right. The notice is not optional documentation — its failure is a qualification error.
- Payroll coded to defer unless the employee affirmatively opts out. The first payroll after eligibility must withhold at the default rate and deposit on the DOL's 7-business-day safe harbor (small plans) or as soon as administratively feasible for larger plans — late deposits are a prohibited transaction.
- Annual re-notice and escalation. Each year, re-notice; each anniversary, escalate by 1% until the target, unless the participant elected a different rate or opted out.
Failure to operate the EACA as written is a plan operational failure — corrected under the IRS's Employee Plans Compliance Resolution System (EPCRS). Missed elective deferrals under auto-enrollment receive a specific correction under Rev. Proc. 2021-30 §.05 as updated (auto-enrollment failures corrected within 9½ months after the plan year generally require a 25% QNEC on the missed deferral plus full match, with nuanced deadlines) — more forgiving than a standard missed-deferral but still a contribution the employer funds.
The Part-Time Rules That Expand Eligibility Behind Auto-Enrollment
Two SECURE-era provisions widen who is eligible to be auto-enrolled, and they directly affect headcount that sponsors assume are not eligible:
- Long-term part-time (LTPT) — SECURE 1.0 §112 + SECURE 2.0 §125: Beginning with plan years after 12/31/2024, an employee who works at least 500 hours in two consecutive 12-month periods (down from three under SECURE 1.0) and meets the age-21 condition becomes eligible to defer. Hours before January 1, 2021 are excluded for vesting; before January 1, 2023 for eligibility counting under the two-year rule.
- Practical effect in 2026: A part-time designer at 18 hours/week (~936 hours/year) easily crosses 500 in year one; a barista at 12 hours/week (~624 hours/year) crosses in year one as well. Many hospitality, retail, and studio employers who classified "under 20 hours = not eligible" will auto-enroll a cohort they previously excluded — each requiring notice, default deferral, and QDIA mapping.
Exclude LTPT and EACA corrections collide: the eligible part-timer who should have been auto-enrolled but wasn't is both an eligibility failure and an auto-enrollment failure — two EPCRS layers, one participant.
Payroll and Administration — The Checklist That Keeps the Plan Qualified
Before the first payroll that includes the new plan or the new hire:
- Adopt or amend the plan document to reflect: super catch-up operational language (or at least no language that caps catch-up below the statutory super), Roth source where high earners will need it, and EACA provisions with the specific default 3–10%, escalation schedule, and QDIA named. Off-the-shelf prototypes from recordkeepers in 2025–2026 contain these — verify the adoption agreement elects them, don't assume the prototype did.
- Configure payroll codes as three distinct sources: pre-tax elective, Roth elective, and Roth super catch-up — with W-2 mapping (Roth catch-up reported as Roth) and with the $145k prior-year wages flag that forces Roth catch-up for the higher-paid. Test with a $0 payroll before the live pay period.
Each pay period:
- Default defer at the EACA rate unless an affirmative election exists — store the election/opt-out with a timestamp and keep the EACA notices with the payroll file, not only with the TPA.
- For ages 60–63, enforce the super cap before the regular cap — payroll that caps catch-up at $7,500 for a 61-year-old denies $3,750 of legal deferral. System logic should be "if attained age 60–63 on 12/31 of calendar year, cap catch-up at $11,250 (indexed)," otherwise $7,500.
- Deposit elective deferrals within the 7-business-day safe harbor for small plans (fewer than 100 participants) — late deposits accrue excise tax and Form 5330 exposure.
At year-end and for testing:
- ADP/ACP testing — auto-enrollment raises participation, which often helps the test, but an influx of LTPT deferrals at 3% with no match can still leave HCEs constrained. New plans that want to avoid testing entirely should pair auto-enrollment with a safe-harbor design (nonelective 3% or basic/enhanced match with required notices) — still requires EACA, but testing relief plus higher HCE deferral headroom.
- Form 5500: EACA status, Roth source, and LTPT hours tracking are not line items, but an operational failure discovered on audit generates a failure on the Form 5500's compliance questions — keep the plan document, notices, payroll withholding audit trail, and QDIA mapping in the same file that supports the 5500.
A Close That Fits Enrollment Season
This month — claim or set up what you have four years to use:
- If you will be 60–63 on 12/31/2026, confirm your 401(k) or 403(b) plan's catch-up cap is $11,250 (2025) / indexed 2026, not $7,500 — and where 2025 wages exceeded ~$150k, confirm the plan accepts Roth catch-up, because the IRS will enforce Roth-only eligible catch-up for high earners starting with 2026 plan years. Miss 2026's super and you cannot make it up at 64 — the window closes by age, not by contribution history.
- If you established a 401(k)/403(b) after 12/29/2022, confirm the plan document has an EACA (3–10% default, 1% escalation to ≥10%, 90-day permissible withdrawal, QDIA) and that the 30–90-day notice went to every eligible employee — including LTPT at 500 hours in two years — before the first auto deferral. A plan without EACA that was required to have one is not a small omission; it is a form defect that must be corrected under EPCRS.
Each payroll — the 90-second check that prevents the correction:
- Auto-enroll unless an opt-out election is on file, withhold at the correct default, escalate to the anniversary, and code super catch-up vs. regular catch-up vs. pre-tax by age at year-end and by the prior-year wages flag for Roth.
The Bookkeeping Connection
Retirement maxima reward the habit that makes plain-text accounting powerful: every hire date, hours count, notice delivery, deferral election, Roth tag, and super-cap by age is a dated, participant-tagged event — not a year-end guess at what was deferred. When eligibility by hours, EACA notices and opt-outs, payroll deferral codes, and plan-document elections live in the same version-controlled ledger that holds Form 5500 workpapers, the story from "hire 03-14, 500-hour LTPT eligible 2026, auto-enrolled 3% QDIA target-date 2055, super catch-up $11,250 Roth for age-61 owner" to "deposits timely, ADP test passed, no missed-deferral QNEC" is traceable and explainable to a TPA who must approve the filing — and to an IRS Employee Plans examiner who will ask for the notice before the number.
