ARTICLE
18 November 2025

Better Late Than Never: IRS Announces 2026 Retirement Plan Cost-of-Living Adjustments

FL
Foley & Lardner

Contributor

Foley & Lardner LLP looks beyond the law to focus on the constantly evolving demands facing our clients and their industries. With over 1,100 lawyers in 24 offices across the United States, Mexico, Europe and Asia, Foley approaches client service by first understanding our clients’ priorities, objectives and challenges. We work hard to understand our clients’ issues and forge long-term relationships with them to help achieve successful outcomes and solve their legal issues through practical business advice and cutting-edge legal insight. Our clients view us as trusted business advisors because we understand that great legal service is only valuable if it is relevant, practical and beneficial to their businesses.
On November 13, the Internal Revenue Service (IRS) released Notice 2025-67, which contains the new dollar limitations for retirement plans that go into effect on January 1, 2026.
United States Employment and HR
Leigh C. Riley’s articles from Foley & Lardner are most popular:
  • within Employment and HR topic(s)
Foley & Lardner are most popular:
  • within Government, Public Sector, Insurance and Coronavirus (COVID-19) topic(s)

On November 13, the Internal Revenue Service (IRS) released Notice 2025-67, which contains the new dollar limitations for retirement plans that go into effect on January 1, 2026. Due to the federal government shutdown, this update came later than normal, leaving Human Resources (HR), payroll, and benefits teams with less time to implement changes.

The new 401(k) plan limits are summarized in the table below:

401(k) Plan Limit 2026 Limit 2025 Limit Change
Elective Deferrals $24,500 $23,500 ↑ $1,000
Catch‑Up (Age 50+) $8,000 $7,500 ↑ $500
"Super" Catch‑Up (Age 60–63) $11,250 $11,250 No change
Roth Catch‑Up FICA Wage Threshold (NEW) $150,0001 $145,0002 ↑ $5,000
Highly Compensated Employee Threshold $160,0003 $160,0003 No change
Key Employee Threshold (Top‑Heavy Plans) $235,000 $230,000 ↑ $5,000
Annual Compensation Limit $360,000 $350,000 ↑ $10,000
Annual Additions Limit (Code section 415(c)) $72,000 $70,000 ↑ $2,000

1 An employee who received $150,000 or more of Social Security wages in 2025 will be subject to the mandatory Roth catch-up requirements in 2026.

2 Although the IRS published a Roth Catch-Up FICA Wage Threshold for 2025, it was not applicable because the requirement to implement mandatory Roth catch-up contributions was not effective in 2025.

3 Compensation paid in the year shown determines who is considered highly compensated in the following year. For example, someone receiving $160,000 of pay in 2025 is considered a highly compensated employee for 2026. And someone receiving $160,000 of pay in 2026 will be considered a highly compensated employee for 2027.

Updated limits for other plan types are as follows:

Plan Type / Limit 2026 Limit 2025 Limit Change
Defined Benefit Plan Annual Benefit Limit $290,000 $280,000 ↑ $10,000
403(b) Elective Deferrals $24,500 $23,500 ↑ $1,000
403(b) Catch-Up (Age 50+) $8,000 $7,500 ↑ $500
403(b) "Super" Catch-Up $11,250 $11,250 No change
457(b) Contributions $24,500 $23,500 ↑ $1,000
SIMPLE Plan Elective Deferrals $17,000 $16,500 ↑ $500
SIMPLE Catch‑Up (Age 50+) $4,000 $3,500 ↑ $500
SIMPLE "Super" Catch‑Up (Age 60–63) $5,250 $5,250 No change
IRA Contributions $7,500 $7,000 ↑ $500
IRA Catch-Up Contributions (Age 50+) $1,100 $1,000 ↑ $100

What should I do now? Given that this update is coming so late in the year, HR professionals should act quickly to:

  • Ensure payroll and HRIS systems will be updated on time to reflect relevant 2026 limits before the first paycheck in January.
  • Revise benefits communication materials, including enrollment guides and intranet pages. If you have already sent out revised materials for 2026 that did not include the 2026 limits, consider sending an email or another short communication to employees to draw attention to the updated limits.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More