For HR leaders, payroll managers, and highly compensated employees trying to stay ahead of SECURE 2.0, one mistake is proving more costly than any other.
What’s tripping people up right now isn’t the rule. It’s the delay in acting on it.
Across the industry, we’ve seen this pattern again and again. Plans know the change is coming. But the assumption that “someone else is handling it” has quietly become the biggest threat to compliance.
No more pre-tax. No more choice.
If your plan or your payroll system isn’t ready, those extra retirement contributions simply won’t happen. Even if employees elected them. Even if everyone thought it was handled.
It’s a straightforward update… until it isn’t. And all the straightforwardness goes out the window once the clock runs out.
Whether you’re a plan sponsor trying to stay compliant, an HCE trying to maximize savings, or the person responsible for making sure payroll and plan design align, this affects you.
In this article, you’ll get a clear breakdown of what’s changing, what to watch for, and the simplest way to stay ahead of the rule—including what your advisor should already be doing to help you avoid a last-minute scramble.
Let’s make this easy.
Under SECURE 2.0, any employee who:
…must make those contributions on a Roth (after-tax) basis starting January 1, 2026.
That means:
Simple in theory. Messy in practice if you wait too long to implement it.
This rule was originally scheduled for 2024, but the IRS granted a two-year delay. That extra time helped, but it also led many to deprioritize this change.
Here’s what you should be doing now:
If you’re over 50 and earn above the HCE threshold, this rule affects your retirement strategy directly.
Even if your employer or advisor handles most of the details, you still have a role to play. Ask now:
The worst strategy you can take is “Let’s all pretend this Roth rule isn’t coming and see how that goes.”
Spoiler: it won’t go well.
Worst-case scenario:
Better-case scenario:
You handle it now, communicate proactively, and check this off your list for good.
This rule doesn’t have to be complicated. The easiest way to keep it that way is to:
If your advisor isn’t helping you plan for this, ask them to start. And if they already are, you’re ahead of most.
If you’re not 100% sure your plan is ready, or just want to confirm that nothing’s slipping through the cracks, we’re happy to take a look. It’s a quick conversation that could save a lot of time (and trouble) down the line. Reach out to the team at Carnegie if you’d like a second opinion or support getting things squared away before 2026.
This change is straightforward, until it isn’t. And the only difference between smooth and stressful is timing. Start now. Communicate with your advisor now. Make this a quick fix, not a compliance fire drill. SECURE 2.0’s Roth-only rule goes live January 1, 2026. Handling it now means thanking yourself later.
For informational and educational purposes only. Opinions are subject to change.
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