WASHINGTON – The Internal Revenue Service today issued frequently asked questions in Fact Sheet 2025-08 regarding the dollar threshold for filing Form 1099-K under the One, Big, Beautiful Bill.
The OBBB retroactively reinstated the reporting threshold in effect prior to the passage of the American Rescue Plan Act of 2021 (ARPA) so that third party settlement organizations are not required to file Forms 1099-K unless the gross amount of reportable payment transactions to a payee exceeds $20,000 and the number of transactions exceeds 200.
Form 1099-K is an IRS information return used to report certain payments to improve voluntary tax compliance. The requirement to file a Form 1099-K can be triggered when payments are received for goods or services through a payment settlement entity.
The main change to 401(k) catch-up contributions for 2026 is that high-income earners aged 50 or older will be required to make their catch-up contributions on a Roth (after-tax) basis. The standard and “super” catch-up contribution limits are also projected to increase due to inflation.
Roth catch-up rule for high earners
Beginning January 1, 2026, employees who meet all of the following criteria must make any catch-up contributions to their 401(k) on a Roth basis:
Age 50 or older during the year.
Contribute to a 401(k), 403(b), or governmental 457(b) plan.
Had FICA wages greater than $145,000 in the previous calendar year from the employer sponsoring the plan.
Consequences of this rule:
Loss of upfront tax deduction: High-income earners will lose the ability to lower their current taxable income with pre-tax catch-up contributions.
Future tax-free withdrawals: In exchange, the catch-up contributions and their earnings will be tax-free in retirement.
Impact on plan availability: If an employer’s plan does not offer a Roth 401(k) option, these high earners will not be able to make any catch-up contributions at all.
Projected 2026 catch-up contribution limits
The official 2026 limits have not yet been announced by the IRS, but experts project the amounts will rise from 2025 due to inflation.
Eligibility
2025 Catch-up Contribution Limit
Projected 2026 Catch-up Contribution Limit
Age 50–59, and 64+
$7,500
$8,000
Age 60–63 (super catch-up)
$11,250
Up to $12,000 (150% of the standard catch-up limit)
Other key details
Secure 2.0 Act: The Roth catch-up requirement for high earners is a provision of the SECURE 2.0 Act of 2022, which was originally set to take effect in 2024 but was delayed until 2026 to give employers more time to prepare.
Employer responsibility: Employers must track prior-year FICA wages to determine which employees are subject to the Roth catch-up requirement. Plans must also offer a Roth option to all employees if they wish to allow high earners to continue making catch-up contributions.
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