2025 comp for 2026 HPI

Are we all agreed that the rule is $145K of FICA wages to be a Highly Paid Individual (or High Earner or whatever your favorite acronym is) for 2026?  I thought I heard something about it being increased for cost-of-living from 2024 to 2025 and that might make it $150K, but I don't see anything official on that.  Thanks.

The Internal Revenue Service has neither published nor released inflation-adjusted amounts for retirement plans for 2026.

Based on recent political news suggesting a potential end to the current application of the Antideficiency Act, some hope the IRS release (not the publication in the Internal Revenue Bulletin) happens by November’s end.

Consultants that have published unofficial calculations concur that a participant is a § 414(v)(7)-affected individual for 2026 if her 2025 Social Security wages were more than $150,000.

My understanding is that the compensation threshold is  a  "Lookback" number.   i.e.  to limit THIS year's catch-ups,  you look back to LAST year's compensation.

That means  ......    the relevant compensation for 2026 catch-ups  is the  2025 compensation, with a threshold of $145,000.

Indexing based on 3rd quarter 2025 CPI  increases the  2026 compensation threshold to   $150,000,   which will be used to determine 2027 catch-ups.

UPDATE  November 13  ........   my original "understanding"  seems to be incorrect.     Notice 2025-67 says to apply the  2026 limit [$150,000]  to the  2025 Compensation being tested.

.....  Jeff

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

The Roth catch-up wage threshold for 2025, which under section 414(v)(7)(A) is used to determine whether an individual’s catch-up contributions to an applicable employer plan (other than a plan described in section 408(k) or (p)) for 2026 must be designated as Roth contributions, is increased from $145,000 to $150,000

So if a participants wages are $150,000 in 2025. Then the participant has to contribute Roth catch-up in 2026? 

50 minutes ago, Bruce1 said:

So if a participants wages are $150,000 in 2025. Then the participant has to contribute Roth catch-up in 2026? 

Yes, for catch-up eligible participants with FICA wages in excess of $150,000

And remember as WCC notes it is FICA wages which are W-2 Box 3. Those could be different from Box 1 wages, 414(s) compensation, 415 compensation or eligible plan compensation.

Guess we got the official answer! I'm just not patient enough.