401(k) Provisions added to Profit Sharing Plan effective 8/1/2026

[Dougsbpc]

Suppose you have a profit sharing plan that covers 15 participants and has for over 10 years.

They would like to add a 401(k) provision 8/1/2026 and make the plan Safe Harbor NEC for 2026.

I would think that since the profit sharing plan has been active since before 1/1/2026, the overall 415 limit for the 401(k) profit sharing plan would be $72,000 for 2026. 

Question: all participants will be under age 50. Since all participants will only be able to start funding salary deferrals on 8/1/2026, must the salary deferral limit be limited to 5/12ths of $24,500 or $10,208? Or could they fund the entire $24,500? And I would think salary deferrals, the 3% SNEC and Profit Sharing contributions to the participant would be based on full year compensation and subject to the overall $72,000 415 limit.

Does anyone see this differently?

Thanks.