FLASHPOINT: NEW COLAS WITH A TWIST! $145,000 OUT, $150,000 IN!
In a twist, the Internal Revenue Service has retroactively changed the Roth Catch-up FICA wage threshold from $145,000 to $150,000. Plan Sponsors must use this limitation to determine who the Highly Paid Individuals (HPIs) are for 2026. These people must make any catch-up contributions as Roth amounts, rather than pre-tax. This new limit should be communicated ASAP to all plan sponsors to ensure they identify the correct HPIs for 2026. See our prior Flashpoints regarding this issue: here and here!
The limits that increased for 2026 are shown below in blue bold italics in the chart below.
The 2026 and prior years’ limits are as follows:
| Limit Type | For Calendar Year | |||
|---|---|---|---|---|
| 2026 | 2025 | 2024 | 2023 | |
| Maximum DB Plan Benefit (IRC §415(b)) (applies to limitation years ending in indicated year) | $290,000 | $280,000 | $275,000 | $265,000 |
| Max DC Annual Addition (IRC §415(c)) (applies to limitation years ending in indicated year) | $72,000 | $70,000 | $69,000 | $66,000 |
| Salary Deferral Limit (IRC §402(g)) | $24,500 | $23,500 | $23,000 | $22,500 |
| Catch-up Limit for 401(k), 403(b), 457 plans (applies to calendar year) | $8,000 | $7,500 | $7,500 | $7,500 |
| Catch-up Limit (age 60-63) for 401(k), 403(b), 457 plans (applies to calendar year) | $11,250 | $11,250 | ||
| Roth Catch-up HPI Limit (IRC §414(v)(7)(a)) | TBD | $150,000 | ||
| HCE Compensation (applies to lookback years in indicated year) | $160,000 | $160,000 | $155,000 | $150,000 |
| Max Plan Compensation for Retirement Plan Purposes (IRC §401(a)(17)) (applies to plan years beginning in indicated year) | $360,000 | $350,000 | $345,000 | $330,000 |
| Key Employee: Officer | $235,000 | $230,000 | $220,000 | $215,000 |
| Key Employee: 1% Owner | $150,000 | $150,000 | $150,000 | $150,000 |
| Social Security Taxable Wage Base for OASDI Contributions | $184,500 | $176,100 | $168,600 | $160,200 |
| Maximum Domestic Abuse Distribution (IRC §72(t)(2)(K)(ii)(1)) | $10,500 | $10,300 | ||
| 457(b) Contribution Limit | $24,500 | $23,500 | $23,000 | $22,500 |
| Starter 401(k) Deferral-only Arrangement Limit | $6,000 | $6,000 | ||
| Starter 401(k) Deferral-only Catch-Up | $1,100 | $1,000 | ||
| SIMPLE Salary Deferral Limit | $17,000 | $16,500 | $16,000 | $15,500 |
| SIMPLE Salary Deferral Limit ( <25 participants or larger election) (IRC §408(p)(2)(E)(i)(l)) | $18,100 | $17,600 | ||
| SIMPLE Catch-up Limit | $4,000 | $3,500 | $3,500 | $3,500 |
| SIMPLE Catch-up Limit (age 60-63) | $5,250 | $5,250 | ||
| SIMPLE Nonelective Contribution Limit | $5,300 | $5,100 | ||
| IRA Contribution Limit (IRC §219(b)(5)(A)) | $7,500 | $7,000 | $7,000 | $6,500 |
| IRA Catch-up Limit (IRC §219(b)(5)(B)(iii)) | $1,100 | $1,000 | $1,000 | |
| SEP Threshold | $800 | $750 | $750 | $750 |
| ESOP: 5-year Distribution Factor | $290,000 | $280,000 | $275,000 | $265,000 |
| ESOP: Account Balance | $1,455,000 | $1,415,000 | $1,380,000 | $1,330,000 |
| Premiums for QLACs (Treas. Reg. §1.401(a)(9)-6(q)(2)(ii)) | $210,000 | $210,000 | $200,000 | $200,000 |
We wish all of you a healthy and prosperous 2026! If you have any questions, please let us know. Remember: we are your ERISA solution!
- Posted by Ferenczy Benefits Law Center
- On November 13, 2025