ICYMI - 2026 expected limits

The CPI-U for July, August, September of 2025 are all published with values of 323.048, 323.976, and 324.800 respectively. Based on Tom Poje's spreadsheet, the dollar limits for 2026 will be:

NOT Official via any IRS pronouncement yet, of course:

Deferral limit: $24,500 (up from $23,500)

Catchup: $8,000 (up from $7,500) (Super-Catchup, age 60-63 = $11,250, (unchanged)

Compensation Limit: $360,000 (up from $350,000)

Annual Addition Limit: $72,000 (up from $70,000)

DB Limit: $290,000 (up from $280,000)

HCE: $160,000 (unchanged)

Key Employee: $235,000 (up from $230,000)

the 2026 HPI comp number should be $150,000 (up from $145,000) It's unclear but my guess is that means in 2027 we look at comp over $150,000 paid in 2026 for determining HPI's in 2027.

The official taxable wage base for 2026, announced by SSA, is $184,500 (up from $176,100).

Do you have an estimated wage compensation cut off for the employer contribution credit for new start-up plans? 

Originally $100,000. 

If you can explain this from Code section 45E, sure:

I estimate the amount remains $105,000 for 2026.

(Organized by Internal Revenue Code section; original amount; rounding increment, and rounding down or nearest; and text of the adjustment provision, with highlighting on the base-period year.)

I.R.C. § 45E(f)(2)(C)(iii)(II) [Small employer pension plan startup costs]; $100,000; $5,000, rounded down; “the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting ‘calendar year 2007’ for ‘calendar year 2016’ in subparagraph (A)(ii) thereof.”

But in November 2024 the IRS stated: “Pursuant to section 45E(f)(2)(C)(iii), for a taxable year beginning in a calendar year after 2023, this limitation is equal to the initial limitation of $100,000, multiplied by the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting ‘calendar year 2007’ for ‘calendar year 2016’ in section 1(f)(3)(A)(ii). Because the specification of a 2007 base period to be used for computing an adjustment that is first made for 2024 appears to be an error that has been identified as the subject of future legislative correction, the IRS will calculate and apply the limitation in section 45E(f)(2)(C) by substituting ‘calendar year 2022’ for ‘calendar year 2007’ in section 45E(f)(2)(C)(iii). Using that substitution, the limitation for 2024 was [and for 2025 is] $105,000. IRS Notice 2024-80, 2024–47 I.R.B. 1120 (Nov. 18, 2024), https://www.irs.gov/pub/irs-irbs/irb24-47.pdf (emphasis added).

from “How to inflation-adjust amounts not designed in Tom Poje’s spreadsheet” https://benefitslink.com/boards/topic/80456-how-to-inflation-adjust-amounts-not-designed-in-tom-poje%E2%80%99s-spreadsheet/#comment-354056.

Robert Richter just stated he believed the next COLA announcement will indicate the HPI determination for 2026. So if the comp number is $150,000 (up from $145,000), he believes that means in 2026 we look at comp over $150,000 paid in 2025 for determining HPI's in 2026.

Mercer's estimates just published this morning:

https://www.mercer.com/insights/law-and-policy/mercer-projects-2026-retirement-plan-limits/