Finally – the 2026 Qualified Plan and IRA Limits are here – see Notice 2025-67. Most notably, for the new Roth catch-up requirement, the Notice confirms that we use the $150,000 (not $145,000) threshold for 2025 FICA wages (Box 3) to determine if catch-ups must be made in Roth (rather than pre-tax) for 2026. The Notice also clarified that the super catch-up limit is still $11,250 for non-simple plans for 2026.
These annual indexed limits are important for a number of purposes – including nonqualified plans eligibility and benefits, open enrollment materials, IRA materials, safe harbor plan notices, etc.
Thank you to the IRS for working on these numbers during the shutdown!
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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.
