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

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.

Since the plan has been active since before 1/1/2026, the full 415 limit is applicable to the sum of all contributions and reallocated forfeitures made during the year.

Elective deferrals must be made from compensation that the participant has not yet received.  A participant could defer the entire $24,500 if the employee makes and election to defer beginning after effective date of the amendment allowing deferrals, and defers that amount from compensation earned after the later of the effective date of the amendment and the effective date of participant's deferral election.