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.
Simplify Your Financial Management
The extra $3,750 lasts four birthdays and the auto-enrollment rule lasts the life of the plan — miss the first and the deferral is gone, miss the second and the qualification is at risk. Beancount.io gives you plain-text, version-controlled accounting where plan elections, participant ages, notice dates, deferral codes by source, and payroll deposits stay explicitly linked — no hidden portals, no vendor lock-in, and AI-ready when you want help turning next quarter's hire roster into next payroll's correct withholding. Get started for free and make the super you can take the super you do take, and the auto-enrollment you must operate the auto-enrollment you can prove.