ARTICLE
10 December 2025

2026 Cost-of-Living Adjustments For Benefit Plans

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Nelson Mullins Riley & Scarborough LLP

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The IRS has released the 2026 cost-of-living adjustments to certain limits, thresholds and penalties that apply to employee benefits plans and programs.
United States Employment and HR
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The IRS has released the 2026 cost-of-living adjustments to certain limits, thresholds and penalties that apply to employee benefits plans and programs. The following charts provide the applicable limits for 2026 in comparison to 2025.

Qualified Retirement Plan Changes for 202612

Provision

2026

2025

Change?

401(k)/403(b) Plans

Annual Limit on Deferrals

$24,500

$23,500

Yes

Annual Catch-up Limit, 50 years or older

$8,000

$7,500

Yes

Annual Catch-up Limit, Age 60-63

$11,250

$11,250

No

Annual Limit on Contributions (DC Plans)

$72,000

$70,000

Yes

General Limits & Thresholds

HCE Prior Year Compensation Threshold

$160,000

$160,000

No

Key Employee Compensation Threshold

$235,000

$230,000

Yes

HCE Roth Catch-up Threshold

$150,000

$145,000

Yes

Annual Compensation Limit

$360,000

$350,000

Yes

ESOP Limits

Amount Balance Limit Subject to 5-Year Distribution Period

$1,455,000

$1,415,000

Yes

Incremental Amount Adding Additional Year(s) to 5-Year Distribution Period

$290,000

$285,000

Yes

Maximum Withdrawal

Domestic Abuse Distribution

$10,500

$10,300

Yes

Qualified Long-term Care

$2,600

$2,600

No

Withdrawal for Emergency Expenses

$1,000

$1,000

No

Defined Benefit Plans

Annual Benefit Limit

$290,000

$280,000

Yes

PBGC Premiums for Defined Benefit Pension Plan for 20263

Premium

2026

2025

Change?

Single Employer

Flat Rate (Per Participant)

$111

$106

Yes

Variable Rate for $1,000 of Unfunded Vested Benefits

$52

$52

No

Per Participant Variable Cap

$751

$717

Yes

Multiemployer Plans (e.g., union)

Flat Rate (Per Participant)

$40

$39

Yes

Deferred Compensation Limit Changes for 2026

Provision

2026

2025

Change?

457(b) Plans4

Annual Limit on Contributions

$24,500

$23,500

Yes

Annual Catch-up Limit

$8,000

$7,500

Yes

409A Deferred Compensation

Specified Employee Compensation Threshold

$235,000

$230,000

Yes

Involuntary Separation Pay Limit

$720,000

$700,000

Yes

Health and Welfare Plan Changes for 20265

Provision

2026

2025

Change?

HDHP & HSA Limits

Annual Deductible – Minimum

$1,700/$3,400

$1,650/$3,300

Yes

Out-of-Pocket Expenses (HSA) – Maximum

$8,500/$17,000

$8,300/$16,600

Yes

HSA Contribution Limit (Individual/Family)

$4,400/$8,750

$4,300/$8,550

Yes

Catch-Up Limit

$1,000

$1,000

No

Flexible Spending Account (FSA)

Health FSA – Employee Contribution Limit

$3,400

$3,300

Yes

Health FSA – Maximum Carryover

$680

$660

Yes

Dependent Care FSA – Employee

Contribution Limit

$7,500 married filing jointly or head of household

$3,750 married filing separately

$5,000 married filing jointly or head of household

$2,500 married filing separately

Yes

Affordable Care Act (ACA) Changes for 2026

Provision

2026

2025

Change?

ACA Limits for Non-Grandfathered Health Plans6

Out-of-Pocket Maximum (Individual/Family)

$10,600/$21,200

$9,200/$18,400

Yes

Embedded Individual Maximum within Family Coverage

$10,150

$9,200

Yes

Affordability

9.96%

9.02%

Yes

Penalties 7

No Offer of Coverage (Penalty A)

$3,340

$2,900

Yes

Coverage Fails Minimum Value or Affordability

$5,010

$4,350

Yes

Incorrect, Late, or Failure to File ACA Reporting Forms

$340

$330

Yes

Incorrect or Failure to Furnish ACA Reporting Forms

$340

$330

Yes

Failure Resulting From Intentional Disregard

$680

$660

Yes

Filing of a Corrected Form within 30 Days After Due Date

Filing a Corrected Form Between 30 Days After Due Date and August 1

$60 per Form

$130

$60 per Form

$130

No

No

Social Security Changes for 20268

2026

2025

Change?

Wage Base

$184,500

$176,100

Yes

Footnotes

1 https://www.irs.gov/pub/irs-drop/n-25-67.pdf.

2 Additional changes apply to SEPs and SIMPLEs that are not addressed in this alert.

3 https://www.pbgc.gov/employers-practitioners/premium-filings/rates.

4 https://www.irs.gov/pub/irs-drop/n-25-67.pdf.

5 https://www.irs.gov/pub/irs-drop/rp-25-19.pdf.

6 https://www.irs.gov/pub/irs-drop/rp-25-25.pdf,https://www.irs.gov/pub/irs-drop/rp-25-26.pdf.

7 https://www.irs.gov/pub/irs-drop/rp-24-40.pdf.

8 https://www.ssa.gov/oact/cola/cbb.html

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.

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