November 2025

State Updates

 

Pension Plan Limitations for 2026 Provided by IRS

12/04/25

Author: ADP Admin/Monday, December 1, 2025/Categories: Compliance Corner , Federal Compliance Update


Highlights

Impacted Employers:
All employers sponsoring 401(k), 403(b), and 457 pension plans.

Effective Date: Jan. 1, 2026

Summary: Pension Plan Limitations for 2026 have been released by the IRS. The 401(k)-contribution limit is increased to $24,500. Any individual making $150,000 or more in FICA wages in 2025 must make catch-up contributions in 2026 on a post-tax basis (Roth).

Next Steps: Update applicable plan documents and summary plan descriptions and communicate 2026 limits to plan participants.



The Details:
 

On Nov.  13, 2025, the Internal Revenue Service (IRS) announced via Notice 2025-67, the cost-of-living adjustments applicable to dollar limitations for pension plans and other items for tax year 2026.   

A summary of the 2026 pension limitations as compared to 2025 is below: 

Plan Maximum Contribution Limits

2025

2026

Section 401(k) Plan or SAR SEP

$23,500

$24,500

Catch-up contributions (if age 50 or older) *

$7,500

$8,000

Catch-up contributions (individuals who attain age 60,61,62 or 63 in 2026) *

$11,250

$11,250

Roth (after tax catch-up contributions) threshold

$145,000

$150,000

Section 403(b) Plan

$23,500

$24,500

Section 408(p)(2)(E) SIMPLE Plan Contributions

$16,500

$17,000

Section 457(e)(15) Limit

$23,500

$24,500

Section 415 Limit for:

Defined Contribution Plans

Defined Benefit Plans

 

$70,000

$280,000

 

$72,000

$290,000

Highly Compensated Employees Section 414(q)(1)(B)

$160,000

$160,000

Key Employee Section 416(i)(1)(A)(i)

$230,000

$235,000

Includible Compensation –

Section 401(a)(17)

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SEP Compensation

SEP Earnings Threshold

 

$350,000

 

$350,000

$750

 

$360,000

 

$360,000

$800

Limited Governmental Plans (pre 7/1/93)

$520,000

$535,000

Section 409 Employee Stock Ownership Plan Subject to 5-Year Distribution Period

Maximum Balance

Amount Used to Determine the Lengthening of the 5-Year Period

 

 

$1,415,000

 

$280,000

 

 

$1,455,000

 

$290,000

 

* For 2026, all catch-up contributions under section 414(v)(7)(A) to an applicable employer plan (other than a plan described in section 408(k) or (p)) must be designated as Roth contributions for individuals earning $150,000 or more in FICA wages in 2025.

 

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