It’s complicated. It doesn’t apply to self-employed because reasons, namely how they defined wages. And the IRS just granted a 2 year administrative delay in a recent Notice saying it won’t treat a plan as failing if it does regular pre-tax catch-up instead of ROTH catch-up for the affect individuals in 2024 and 2025.
But it is coming. Why on earth they came up with a new $145K number to track instead of tying it to the HCE limit which would have been $150K is beyond me.