The 2026 limits are posted. They are not in force yet.

The notice this briefing refused to invent on November 9 was posted four days later. On November 13, 2025, the Internal Revenue Service released IR-2025-111 and the technical tables in Notice 2025-67. The 2026 limits are now knowable. They are not in force. For a calendar-year plan they take effect on January 1, 2026. Today is November 23. Anything you defer, accrue, or deduct for 2025 still uses the 2025 table. The useful work this week is to write the deltas down correctly and to keep them out of the current-year file.

Sterling Pension Group is a third-party administrator and pension consultant. We are not an actuarial firm. An independent Enrolled Actuary certifies the minimum contribution, the deductible maximum, and Schedule SB. A cost-of-living table is not that certification. This briefing is not tax, legal, or actuarial advice. It is a reading of the rows that change a self-employed owner's 2026 design, and a warning about using them five weeks early.

What moved, against the 2025 baseline

The elective deferral limit rises from $23,500 to $24,500. That is the cap on what a participant may defer into a 401(k), 403(b), governmental 457, or the Thrift Savings Plan during the calendar year, before catch-up. The first payroll that may use $24,500 is a 2026 payroll. A deferral taken from wages paid in 2025 is still capped at $23,500, even if the payroll company has already loaded next year's table into a test file.

The ordinary catch-up limit, for a participant who is age 50 or older and not in the special age band, rises from $7,500 to $8,000. Added to the new deferral limit, that is $32,500 of employee deferrals for someone who is 50 or older and using the ordinary catch-up, starting in 2026. Catch-up contributions still do not count against the defined contribution annual-additions limit. Do not let a payroll summary fold the catch-up into the annual-additions figure and then tell you that you have over-contributed.

The higher catch-up for ages 60, 61, 62, and 63 does not rise. It remains $11,250. That was the figure in 2025, and Notice 2025-67 leaves it there for 2026. A participant who will be 60, 61, 62, or 63 in 2026 does not get $8,000 plus $11,250. The higher figure replaces the ordinary catch-up. Someone who is 59 this year and turns 60 in 2026 should be coded to the higher catch-up for 2026 pay, not for the last paycheck of 2025. Someone who turns 64 in 2026 falls back to the ordinary catch-up of $8,000. Age is measured carefully. "Around 60" is not a payroll code.

The defined contribution annual-additions limit rises from $70,000 to $72,000. That is the ceiling on annual additions to a defined contribution account, other than catch-up. In a 401(k) profit-sharing plan it is the combined room for deferrals and employer money, before catch-up is stacked on top. It is not a pension contribution limit. It never was. A one-year increase of $2,000 will not be the reason a cash balance plan does or does not fit.

The compensation cap rises from $350,000 to $360,000. This is the pay a qualified plan may take into account for allocations and for benefit formulas in 2026. It is not a salary you are required to pay yourself. If W-2 wages or earned income stay below the cap, the plan uses the lower number. The extra $10,000 of countable pay matters only if you earn it, and only in the year the new cap applies. It does not increase a 2025 credit that was computed on $350,000 or on whatever you actually earned.

The defined benefit dollar limit rises from $280,000 to $290,000. Read it as a benefit limit. The IRS states the structure on its defined benefit limits page: a cap on the annual benefit, generally as a life annuity at retirement age, coordinated with the 100 percent of average compensation limit, and reduced when the law requires a reduction for early commencement or for fewer than ten years of participation. It is not a permitted deposit of $290,000, and the $10,000 increase is not a $10,000 increase in the contribution. The contribution is a function of age, the document's formula, the interest crediting rate, compensation, and the certified deductible maximum. A cash balance plan expresses that benefit as a hypothetical account. The COLA did not turn the account into a defined contribution plan with a published maximum deposit.

The IRA limit rises from $7,000 to $7,500. The IRA catch-up, which had sat at $1,000, rises to $1,100. Those are personal IRA figures. They are announced in the same release because the IRS announces them together. They are not lines in the employer's plan, and they do not increase what the practice may deduct for a cash balance contribution. Keep them on the personal return. Publication 560 is still the right overview to hand a CPA who wants the small-business context; the notice, not the booklet, is the authority for the dollars.

The standing table, which will show 2025 and 2026 side by side once the site is updated, is the IRS COLA increases page. If a vendor's PDF and that page diverge, use the IRS page and Notice 2025-67. Do not average them.

What did not happen on November 13

The release did not change the 2025 limits. A deferral already withheld this year is tested against $23,500 and the 2025 catch-up that applied to your age. A pension credit for the 2025 year is tested against the $280,000 benefit limit and the $350,000 compensation cap. An independent Enrolled Actuary who is finishing a 2025 valuation does not substitute $290,000 because the notice is interesting. If a draft report arrives with the new limit on a 2025 column, send it back.

The release did not make catch-up contributions Roth. That operational change arrives on January 1, 2026, for participants whose prior-year FICA wages from the sponsoring employer exceed $150,000. It was delayed through 2025. A catch-up withheld from a December paycheck can still be pre-tax if the plan and the election say so. The cash balance pay credit is untouched either way. It is employer money under the pension formula. It is not a catch-up, and it does not become Roth because the participant's wages are high. We will treat the Roth rule in a later briefing. Do not "get ahead of it" by amending the pension.

The release did not fund the plan, file Form 5500, or determine whether the Pension Benefit Guaranty Corporation covers you. Minimum funding for a calendar-year defined benefit plan is generally due September 15 of the following year. The Form 5500 is generally due July 31, extended to October 15. The IRS Form 5500 corner and the Department of Labor's filing guidance describe the return. The PBGC's coverage page describes a plan-specific question. None of those agencies moved their deadline because a limit moved by a thousand dollars.

The release also did not publish a maximum cash balance contribution by age. Anyone who forwards the notice with a sentence like "so you can put in X next year" has left the notice and entered an illustration. If a figure of that kind is used at all, it has to be labeled illustrative, tied to stated assumptions, and replaced by a certified range before a CPA relies on it. The illustrations page is for that kind of picture. The limits page is for the statutory table. They are not the same page, and this notice belongs on the second one until an actuary writes the first.

How to use the next five weeks

Payroll is the practical consumer of the deferral and catch-up changes. Ask the 401(k) provider when the 2026 limits will be loaded, and ask them to confirm that 2025 pay dates remaining in November and December will not pick up $24,500. Ask how a participant who turns 60 in 2026 will be coded, and how a participant who turns 64 will lose the $11,250 catch-up. Ask whether the plan document's definition of compensation and its deferral procedures need an amendment, or whether the limits incorporate by reference. Many documents do incorporate by reference. Some do not. "The IRS raised it" is not an amendment.

The compensation cap and the benefit limit are the actuary's inputs for the 2026 plan year, not a reason to reopen 2025. If a combo is being designed now for a year that has not started, the new table is the right table. If the design is for 2025, it is the wrong table. Say the year out loud in every email. Owners lose a week every November to a thread in which one adviser meant the year of the deduction and another meant the year the deposit will clear the bank.

Compare the new defined contribution room with the pension rather than adding them. In 2026, $72,000 is the annual-additions limit. A cash balance credit is not stuffed into that $72,000. It lives under the benefit limit of $290,000, as funded under the document. When both plans cover the same people, the deduction may be constrained by the combined-plan rule, and PBGC coverage may change that constraint. The enrolled actuary computes the deductible maximum. You should not compute it by adding $72,000 to an illustration and then adding catch-up because the sum looks like a headline. The comparison of a SEP, a 401(k), and a pension is worth rereading if the notice has you shopping structures again. A SEP does not become a pension because the IRA limit moved, and a pension does not become simple because the deferral limit moved by $1,000.

If you are a physician, dentist, attorney, or consultant, the notice did not create a special limit for the profession. The same table applies. What differs is the census, the entity, and whether a professional-service employer exception might matter for PBGC. Those facts were true on November 12. They are true today. Profession-specific overviews — for physicians, dentists, attorneys, and consultants — are about the shape of the practice, not about a private COLA.

Leave the Roth catch-up implementation on the 2026 list. Between now and year-end, confirm whether any participant, including you, will have 2025 FICA wages from the sponsoring employer over $150,000. That is the test the rule will apply in January. It is not a 2025 withholding change. Partners and sole proprietors who have no FICA wages from the sponsor are often outside the rule. S corporation owners who take W-2 wages can be inside it. The 401(k) provider and the CPA have to sort the wage definition. The pension formula does not.

What to do in the next two weeks

Send IR-2025-111, not a rewritten bullet list, to the CPA and the 401(k) provider. In the same note, state that 2025 deposits and 2025 deferrals remain on the 2025 limits: deferrals $23,500, ordinary catch-up $7,500, ages 60 through 63 $11,250, annual additions $70,000, compensation $350,000, defined benefit dollar limit $280,000. Ask the provider for the date the payroll file switches, and ask them to confirm December will not switch early.

Ask the pension side to keep any 2025 range on the 2025 benefit limit. If you want a 2026 illustration, ask for it under the new table, with your age and your expected compensation, and keep the word illustrative on it until an Enrolled Actuary certifies a range. Bring both years labeled if you want that work coordinated. Two weeks from today is December 7. The limits will still not be in force. The Roth catch-up rule will be closer. Neither fact is a reason to put $24,500 on a 2025 paycheck.