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How Roth 401k plan catch-ups will change in 2026

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After delaying a rule requiring high-income 401(k) savers aged 50 or older to make catch-up contributions in Roth accounts, the IRS has signaled that it will take effect starting next year.

That gives financial advisors working with 401(k) sponsors or clients earning more than $145,000 less than two months to ensure a Roth account is available and help those clients decide whether to contribute to it, noted Jay Cirame, vice president of ERISA consulting at Sentinel Group, a Wakefield, Massachusetts-based registered investment advisory firm. The IRS confirmed in September that traditional 401(k) plan catch-up contributions will no longer be available for those above the income threshold, after its 2023 relief from the rule pushed the Secure 2.0 Act provision’s effective date to 2026.

Industry trade groups had pressed for the extended transitional period, warning that many sponsors, administrators and recordkeepers needed more time to set up after-tax Roth plans alongside the traditional tax-deferred 401(k) plans and make other technical changes. The “system challenges for the industry as a whole” require 401(k) sponsors and their advisors to coordinate with their payroll companies and recordkeepers on any final steps while working to educate higher-earning participants about the shift in the guidelines, Cirame said.

“For 2026, you need to apply the rule under good faith efforts. That essentially means you’ll be diligent and reasonable in applying the new rule,” he said. “Each employee needs to consider their own tax implications as to whether they want to contribute the catch-up without the current-year tax break but enjoying the favorable tax benefits long-term.”

READ MORE: Elephant IRAs: Why wealthy clients face tax risks (even with Roths)

What the rules say

However, savers who are 50 or older and earning more than $145,000 from their job in 2025 won’t get any catch-ups in 2026 if their plans do not offer the widely (but not universally available) Roth 401(k) accounts, he added. For context, Vanguard’s latest snapshot report shows at least 86% of its 401(k) plans, which cover 96% of participants that use the giant investment firm’s employer retirement savings accounts, offered a Roth 401(k) last year. But only 18% of the workers who had access to a Roth 401(k) used it, and just 16% of all Vanguard 401(k) participants contributed a catch-up payment last year. Of those with incomes of $150,000 or more, though, the share who made a catch-up contribution was 51%.

This year, 401(k) savers at any age may contribute as much as $23,500 into the traditional tax-deferred or Roth account. 

As long as their employee earnings do not go above $145,000, those 50 or older can set aside another $7,500 in their tax-deferred 401(k) as their catch-up, with a “super catch-up” of another $3,750 to a total of $11,250 available to workers aged between 60 and 63 years old, according to a blog last month by Joanie Stein of Berkowitz Pollack Brant Advisors + CPAs. Ultimately, those traditional 401(k) participants will face taxes upon the withdrawal of their holdings, with required minimum distributions kicking in at age 73. Those steering their savings into Roth 401(k) accounts will have already paid taxes on the income, so they can withdraw from the holdings with no further duties beginning at age 59 and a half and have no required distributions at any age, Stein noted. Those attributes explain why many tax and retirement experts viewed high-earners’ loss of the traditional catch-up option as something of a blessing in disguise.

“Workers in their 50s or 60s, who may be at the height of their earnings potential, will lose a tax deduction for their 401(k) catch-up contributions and the ability to reduce their taxable income for tax years beginning in 2026,” Stein wrote. “Moreover, a higher taxable income may affect the taxpayers’ eligibility for other deductions, including those for state and local tax payments, charitable donations and qualified business income. On the other hand, the ability to escape RMDs and taxes on withdrawals in the future via Roth contributions today could be especially appealing to those individuals who expect to remain in a high tax bracket in retirement and have significant assets to pass on to future generations.”

READ MORE: Should clients near retirement reconsider withdrawal strategies?

Elect now, save later

Experts predict that the limits on contributions will increase in 2026 due to inflation, but the IRS hasn’t yet released the exact figures. In the meantime, small business owners who have multiple companies within a so-called controlled group can elect whether or not to combine a worker’s wages and contributions across those employers for the purposes of the rules, Cirame noted. And the high earners have more incentive to start a Roth 401(k) account right away in 2026.

“It would be most advantageous for them to elect Roth at the beginning of the year,” Cirame said. “If you start doing that in January, that means that the earnings will grow for an even longer period. That’s why I think it’s beneficial to do that at the beginning of the year, instead of waiting until the end to make that election.”

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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Accounting

Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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Accounting

Automated Tax Compliance and Global Regulatory Harmonization in 2026

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Corporate tax accounting departments are navigating an era of unprecedented regulatory complexity as global tax harmonization frameworks take full effect alongside real-time digital tax reporting mandates. Tax directors and accounting teams are adopting cloud-based tax compliance automation tools to manage multi-jurisdictional tax liabilities and satisfy stringent reporting rules across international jurisdictions.

Implementation of Global Minimum Tax Provisions
The implementation of international tax reform agreements—notably the Pillar Two global minimum tax framework—has reshaped multinational corporate tax planning. Multinational enterprises with consolidated revenues exceeding established thresholds must ensure an effective tax rate of at least 15% across every jurisdiction in which they operate.

Accounting teams are implementing specialized tax calculation modules integrated directly into enterprise resource planning (ERP) platforms. These automated tools calculate effective tax rates per country, identify top-up tax liabilities, and generate standardized compliance documentation required by national tax authorities.

Real-Time Digital Invoicing and E-Reporting Mandates
Tax authorities across Europe, Latin America, and Asia-Pacific have enacted mandatory electronic invoicing (e-invoicing) and continuous transaction controls (CTC). Under these systems, corporate transaction data must be submitted electronically to government portals in real time at the point of sale or invoice issuance.

This shift toward continuous digital tax reporting eliminates traditional annual tax audits in favor of ongoing automated compliance monitoring. Accounting departments are upgrading invoicing software to ensure seamless XML data formatting, digital signature authentication, and real-time validation against tax authority databases.

Automation and Data Analytics in Corporate Tax Strategy
To keep pace with dynamic tax legislation, tax departments are transitioning from reactive compliance teams to proactive strategic advisors. Machine learning algorithms analyze corporate transactional data to identify tax credits, research and development (R&D) incentives, and cross-border transfer pricing adjustments.

By automating routine tax return filings and calculations, corporate tax directors can focus on long-term capital structuring, evaluating the tax implications of corporate mergers, and optimizing international supply chain networks.

Strategic Priorities for Tax Executives
1. ERP System Upgrades: Ensure enterprise software is capable of generating real-time, granular tax data required for global minimum tax compliance.
2. E-Invoicing Integration: Implement scalable e-invoicing platforms to satisfy regional continuous transaction control regulations.
3. Strategic Tax Analytics: Utilize predictive tax modeling tools to evaluate structural changes in corporate operations and cross-border trade.

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