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RESOURCE · UPDATED OCTOBER 2026

2026 401(k) limits and compliance deadlines for TPAs.

The figures a TPA uses in testing, payroll validation and annual administration for 2026, and the dated deadlines for a calendar-year 401(k) plan. Every number links to its IRS or DOL source.

2026 DOLLAR LIMITS

The limits that drive testing and processing.

These are the 2026 cost-of-living adjustments published in IRS Notice 2025-67 and summarized on the IRS COLA limits page. Checked against both on October 25, 2026.

LimitCode section20252026Where a TPA uses it
Elective deferrals402(g)(1)$23,500$24,500Payroll validation, excess deferral refunds
Catch-up, age 50 and over414(v)(2)(B)(i)$7,500$8,000Catch-up eligibility and recharacterization
Catch-up, ages 60 to 63414(v)(2)(E)$11,250$11,250Replaces the age-50 amount for ages 60 to 63
Annual additions415(c)(1)(A)$70,000$72,000415(c) testing, excess annual additions
Compensation limit401(a)(17)$350,000$360,000Allocation and testing compensation caps
Highly compensated employee414(q)(1)(B)$160,000$160,000HCE determination for ADP/ACP testing
Key employee (officer)416(i)(1)(A)(i)$230,000$235,000Top-heavy testing
Roth catch-up wage threshold414(v)(7)(A)$145,000$150,000Who must make catch-ups as Roth
Defined benefit limit415(b)(1)(A)$280,000$290,000Combo and cash balance designs
SIMPLE deferrals408(p)(2)(E)$16,500$17,000SIMPLE 401(k) and IRA plans
WHAT CHANGED FOR 2026

Mandatory Roth catch-up is now an operations problem.

SECURE 2.0 section 603 requires catch-up contributions to be made as Roth for participants whose prior-year FICA wages from the employer exceeded the indexed threshold, $150,000 for the 2026 determination. For a TPA this means three new checks every payroll cycle: identify affected participants from prior-year Box 3 wages, confirm the plan offers Roth deferrals, and flag pre-tax catch-ups for those participants before they post.

  • Collect prior-year FICA wages with the census, not just plan compensation.
  • Validate each payroll file for pre-tax catch-ups from affected participants.
  • Keep a record of how each correction was made if a pre-tax catch-up slips through.

KinetiPlan's payroll validation workflow shows how rule checks at upload catch problems like this before posting.

CALENDAR-YEAR PLAN DEADLINES

The 2026 dates a TPA works to.

For a plan with a December 31 plan year end. Plans with other year ends shift each date by the same offset. Weekend and holiday rules can move a filing date to the next business day.

DateWhat is dueRuleSource
January 31Form 1099-R to participants for 2025 distributionsBy January 31 after the distribution yearIRS
March 15ADP/ACP corrective distributions for 2025 without the 10% excise tax2½ months after plan year end (6 months for an EACA plan)IRS fix-it guide
April 1First required minimum distribution for participants who reached RMD age in 2025 and are no longer working, unless the plan allows deferralRequired beginning dateIRS
April 15Refunds of 2025 excess deferrals over the 402(g) limitApril 15 after the deferral yearIRS fix-it guide
July 31Form 5500 or 5500-SF and Form 8955-SSA for 2025, or Form 5558 to extendLast day of the 7th month after plan year endDOL
September 30Summary annual report to participants, if the 5500 was not extended9 months after plan year endDOL
October 15Extended Form 5500 and 8955-SSA2½-month extension with Form 5558DOL
Early October to early DecemberSafe harbor and automatic enrollment notices for 202730 to 90 days before the plan year startsIRS
December 15Summary annual report when the 5500 was extended2 months after the extended 5500 deadlineDOL
December 31Last day to correct 2025 ADP/ACP failures under the plan's own correction rules, and 2026 RMDs for participants past their first RMD yearEnd of the following plan yearIRS fix-it guide
FROM DATES TO WORK

A deadline is only useful if someone owns the task behind it.

Each date above depends on earlier work: the March 15 refund needs testing done in February, which needs a clean census in January. A TPA with plans on different year ends is tracking hundreds of these chains at once.

  • Work backward from each deadline to the census, testing and review tasks it needs.
  • Give every task one owner and a due date ahead of the regulatory date.
  • Keep the evidence: the test run, the approval and the filing confirmation.

Model what that work costs your team today with the capacity simulator, or see how an ADP failure becomes a corrective distribution.

SOURCES

Primary sources used on this page.

FAQ

Common questions

What is the 2026 401(k) elective deferral limit?

$24,500 under IRC 402(g), up from $23,500 in 2025, per IRS Notice 2025-67. Participants aged 50 or older can add an $8,000 catch-up, and participants aged 60 to 63 can use an $11,250 catch-up instead.

What is the 2026 HCE threshold?

$160,000 under IRC 414(q)(1)(B), unchanged from 2025. For 2026 HCE determinations, the look-back year compensation test uses the threshold in effect for that look-back year, so check which year's figure your plan's determination needs.

Who must make Roth catch-up contributions in 2026?

Under SECURE 2.0 section 603, participants whose prior-year FICA wages from the employer exceeded the indexed threshold must make catch-up contributions as Roth. Notice 2025-67 sets that threshold at $150,000. Confirm your plan's operational approach and final regulations with counsel.

When is the deadline for ADP/ACP corrective distributions without the excise tax?

Within 2½ months after the end of the plan year, which is March 15 for a calendar-year plan (6 months for a plan with an eligible automatic contribution arrangement). Corrections made later, up to the end of the following plan year, carry a 10% excise tax on the employer.

When is Form 5500 due for a calendar-year plan?

By the last day of the 7th month after the plan year ends, July 31 for a calendar-year plan. Filing Form 5558 extends the deadline by 2½ months, to October 15.

FROM REFERENCE TO WORKFLOW

See how KinetiPlan turns these rules into daily work.

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