Summary of Key Issues and Decisions for Plan Sponsors 1 Topic What's Changing Plan Sponsor Actions Timeline for Implementation Catch-Up Contributions Must be Roth for higher paid participants starting in 2026 Decide whether to allow Roth contributions in your plan By the end of 2025, so that it is in effect for 2026 Coordination with Providers Payroll and recordkeepers must properly process Roth catch-up deferrals Notify and align systems and procedures No later than December