As you may recall, in addition to the numerous states Ice Miller represents for employee benefit matters, we also represent the Miller United Pension System in the fifty-first state of Iceville. The Miller United Pension System, which administers all pension benefits for Iceville’s capital Miller City, has enlisted our help to explain to its Board of Trustees how the maximum dollar limits that apply to its defined contribution retirement plans interact. This article is intended to explain how the updated maximum dollar limits work across multiple defined contribution retirement plans. In addition to contribution limits, the IRS recently updated the 401(a)(17) compensation limit ($360,000 for 2026). Look for future advice from Ice Miller to the Miller United Pension System on how this compensation limit works!

Annually, the IRS releases updated indexed limits and cost-of-living adjustments for the upcoming tax year, impacting corners of the Internal Revenue Code from income tax deduction rates to retirement plan contribution limits. Calculations for the adjustments begin following the federal fiscal year close on September 30, utilizing data points, such as the Consumer Price Index, from the prior fiscal year.

On November 13, 2026, the IRS released updated indexed limits to take effect on January 1, 2026. To assist plan sponsors, Ice Miller’s updated Maximum Dollar Limits chart lists the cost-of-living adjustments to retirement plan limitations for the years 2016 through 2026. We hope that this chart (which includes the adjusted limits, as well as Social Security and Medicare contribution rates, and taxable wage bases for the past ten years) will serve as a helpful reference tool.

To maintain tax-qualified status, plans must comply with contribution and compensation limits, which apply to benefits paid from defined benefit plans and to employer contributions, mandatory employee contributions, and employee elective deferrals made to defined contribution plans.¹ Contribution limits must be met by all plan members. If even one member contributes more than the applicable limits allow, the entire plan is at risk of disqualification.²

While some systems do not have to worry about how various contribution limits interact with each other, systems (or participating employers in systems) that offer multiple retirement plans must understand how some limits may be reduced by others. The Miller United Retirement System offers the following plans:

• a 401(a) defined benefit plan, which is the primary retirement plan for teachers and public safety employees, and which provides for mandatory employee contributions that are picked-up (pre-tax) and employer contributions; 
• a 401(a) defined contribution money purchase pension plan, which is the primary retirement plan for other state employees, and which provides for mandatory employee contributions that are picked-up (pre-tax) and employer contributions;³ 
• a grandfathered 401(k) plan to which all state employees may voluntarily make elective deferrals;  
• a 403(b) plan to which all teachers may voluntarily make elective deferrals; and 
• a 457(b) plan to which all state employees may voluntarily make elective deferrals.

There are some new trustees on the Board of Miller United Retirement System, and a lot of plans to administer, so their General Counsel asked us to provide an overview of how the limits that apply to its defined contribution plans interact.

415(c) Total Contribution Limits

For the 2026 calendar year, the defined contribution plan limit that applies to both 401(a) plans and 403(b) plans⁴ under Code § 415(c) is $72,000 (or, if less, 100 percent of the participant’s compensation⁵).

All 401(a) (including grandfathered 401(k) plans) that an employer offers its employees must be aggregated for purposes of this limit.⁶ Additionally, all 403(b) plans that an employer offers its employees must be aggregated for purposes of this limit. However, 401(a) plans are generally not aggregated with 403(b) plans for purposes of the 415(c) limit; rather the limit generally applies separately to each type of plan.⁷ Therefore, the first step in applying the 415 limits is to identify all plans offered by an employer that are required to be aggregated for testing purposes.

Annual additions made or deemed to be made to a 401(a) or 403(b) defined contribution plan (and any plan required to be aggregated with that plan) are counted toward the limits under Code § 415(c). “Annual additions” include:

• All employer contributions, employee contributions (voluntary and mandatory, pre-tax and post-tax (including after-tax and Roth));⁸ 
• Amounts allocated to an individual medical account, which is part of a pension or annuity plan maintained by the employer or a related employer under Code § 401(h);⁹ 
• Amounts derived from contributions paid or accrued, which are attributable to post-retirement medical benefits, allocated to the separate account of a key employee under a welfare benefit fund;¹⁰ 
• Employee contributions to a defined benefit plan maintained by the employer or a related employer, unless the contributions are picked-up by the employer (pre-tax),¹¹ and
• Employee contributions to a defined benefit plan maintained by the employer or a related employer made on an after-tax basis for permissive service credit purchases under Code § 415(n) (that are tested under the Code § 415(c) dollar limit).

However, annual additions do not include an employee’s age 50 catch-up contributions (including super catch-ups) to a 403(b) or 401(k) plan.¹²

For example, Sam Stacker, a school administrator for Miller City earning $100,000, may have $72,000 contributed to the Miller United Retirement System 401(a) money purchase pension plan in 2026, regardless of any elective deferrals that Sam makes to the 403(b) plan. However, if Sam instead makes elective deferrals to the grandfathered 401(k) plan, any deferrals up to the regular deferral limit ($24,500 for 2026) must be aggregated with the contributions to the 401(a) money purchase pension plan, so that the total contribution to both plans in aggregate is no more than $72,000 for 2026.

402(g) and 414(v) Elective Deferral Limits for 403(b) and Grandfathered 401(k) Plans

Employees may elect to make pre-tax elective deferrals, Roth elective deferrals, and/or both to a 403(b) plan and/or grandfathered 401(k) plan.¹³

Elective deferrals are subject to a regular contribution limit under Code § 402(g). The regular limit for 2026 is $24,500.¹⁴ A participant in a 403(b) plan who has at least 15 years of service with a qualified employer may also be eligible to defer up to an additional $3,000 to the 403(b) plan as a 15 years of service catch-up contribution under Code § 402(g)(7).¹⁵

In addition, participants who will be age 50 or older by the end of the year can make an age 50 catch-up contribution above the regular limit under Code § 414(v). The 2026 age 50 catch-up limit under Code § 414(v) is $8,000. A participant who attains age 60, 61, 62, or 63 during a calendar year is instead eligible for a “super catch-up” equal to $11,250 in 2026.¹⁶ For the calendar year in which a participant attains age 64, the regular age 50 catch-up limit applies again ($8,000 for 2026).¹⁷

The 402(g) and 414(v) limits apply in aggregate to elective deferrals made to a 403(b) plan and to a grandfathered 401(k) plan. Accordingly, if an employee participates in both a 401(k) plan and a 403(b) plan for the same year, the combined limit for 2026 would be $24,500, rather than $49,000, and the participant can use the age 50 catch-up limit only once.

As discussed above, elective deferrals up to the regular limit under Code § 402(g) reduce the defined contribution plan contribution limit under Code § 415(c). However, age 50 catch-up contributions (including super catch-ups) do not reduce the 415(c) limit.

Total Contribution Limit for 457(b) Plans

Employees may elect to make pre-tax elective deferrals, Roth elective deferrals, and/or both to a 457(b) plan.¹⁸

Total contributions to a 457(b) plan, regardless of whether an employee elective deferral or employer contribution, may not exceed the basic limit under Code § 457(b)(2) for a plan year.¹⁹ The 2026 limit for annual contributions to a 457(b) plan is $24,500.²⁰ A participant in a 457(b) plan may also be eligible for a catch-up contribution for the three taxable years prior to the taxable year in which the participant attains normal retirement age (as defined in the 457(b) plan) under Code § 457(b)(3). This maximum special retirement catch-up contribution limit of $24,500 for 2026 depends on the participant’s under-utilized deferral amounts for prior years.

In addition, participants who will be age 50 or older by the end of the year can make catch-up contributions above the regular limit under Code § 414(v). The 2026 age 50 catch-up limit under Code § 414(v) is $8,000. A participant who attains age 60, 61, 62, or 63 during a calendar year is instead eligible for a “super catch-up” equal to $11,250 in 2026.²¹ For the calendar year in which a participant attains age 64, the regular age 50 catch-up limit applies again ($8,000 in 2026).²² A participant can take advantage of the largest of the catch-up contribution limits available.

Although the applicable dollar limit is the same as the Code § 402(g) limit that applies to 403(b) plans and 401(k) plans, it is a completely separate limit. Contributions to a 403(b) or 401(k) plan are not aggregated with contributions to a 457(b) plan. In addition, participants are eligible to take advantage of the Code § 414(v) age-50 catch-up limit (including super catch-ups) under both a 457(b) plan and a 403(b) or 401(k) plan. Lastly, contributions to a 457(b) plan do not reduce contributions to a 403(b) plan or 401(a) plan (including a 401(k) plan) under Code § 415(c).

Let us revisit Sam, the 61-year-old Miller City school administrator. Assume that Sam makes $150,000 annually, and that the 401(a) Money Purchase Plan requires a 7 percent employer contribution and a 10 percent employee mandatory contribution. Assume also that Sam is not eligible for the 457(b) special retirement catch-up, that he is eligible for a $3,000 15 years of service catch-up under the 403(b) plan, and that he chose not to participate in the grandfathered 401(k) plan. Sam may stack contributions as follows:

*If Sam was eligible for the special retirement catch-up, that limit (up to $24,500, depending on under-utilized deferrals) would apply instead of the $11,250 super catch-up limit.

**By application of the Plan’s contribution rates (10 percent x $150,000) + (7 percent x $150,000) = $25,500.

Hopefully, the staff and participants at Miller United Retirement System are all ready for the 2026 retirement plan limits! If they’re not, or if your retirement plan needs some assistance, please contact Audra J. Ferguson, Robert L. Gauss, Nicole Giambarrese, Lisa Erb Harrison, Lindsay Knowles, Rachel Mattingly Phillips, Stanley D. Prybe, Shalina Ann Schaefer, Tara Schulstad Sciscoe, or the Ice Miller Employee Benefits lawyer with whom you regularly work.

^{[1] See Code § 401(a)(16), which requires compliance with Code § 415, and Code § 401(a)(17). 
[2] However, the IRS Employee Plans Compliance Resolution System (“EPCRS”) program, most recently updated under Revenue Procedure 2021-30, 2021-31 IRB 172, as well as the Code and Treasury Regulations provide mechanisms for correction to avoid this result. 
[3] Governmental employers can sponsor a 401(k) plan only if the plan was adopted by the employer prior to May 6, 1986. 
[4] 457(b) plans are not subject to the 415(c) limit, and contributions to a 457(b) plan are not aggregated with contributions to a 401(a) or 403(b) plan.
[5] For purposes under this limit, compensation is defined in Code § 415(c)(3).
[6] Code § 415(g) 
[7] Aggregation is required between a 401(a) and a 403(b) plan in the limited circumstance where a 403(b) plan participant owns or controls more than 50 percent of another employer and that employer maintains a 401(a) or 401(k) plan.
[8] Code § 415(c)(2)
[9] Treas. Reg. § 1.415(c)-1(a). Note the individual medical account must meet the requirement in Code § 415(l)(2).
[10] Treas. Reg. § 1.415(c)-1(a). Key employees must meet the definition of Code § 419A(d)(3). The welfare benefit fund must be compliant with Code § 419(e).
[11] Treas. Reg. § 1.415(c)-1(a). Note that all pick-up contributions must be compliant with Code § 414(h)(2).
[12] Annual additions also do not include rollover contributions, or excess elective deferrals that are distributed in accordance with Treasury Regulation § 1.402(g)-1(e)(2) or (3). See Treas. Reg. § 1.415(c)-1(b). 
[13] Treas. Reg. §§ 1.401(k)-1(a), 1.401(k)-1(f), 1.403(b)-2(b)(17), 1.403(b) -3(c)
[14] Note that this limit is under Code § 402(g). In a 403(b) or 401(k) plan, a participant’s deferrals could be limited by their compensation as described in the 415(c) section above, but not by application of Code § 402(g).
[15] The 15 years of service catch-up may be less than $3,000 for a calendar year depending on prior elective deferrals made to the 403(b) plan on behalf of the employee. This limit is also subject to an overall lifetime limit of $15,000. Code § 402(g)(7); Treas. Reg. § 1.403(b)-4(c)(3).
[16] This super catch-up limit first became effective January 1, 2025, under SECURE 2.0. Code § 414(v)(2).
[17] The age 50 catch-up contribution applies after the 15 years of service catch-up contribution, if a participant qualifies for both.
[18] Treas. Reg. § 1.457(b)-4(b)(2)
[19] Code §§ 457(b)(2), 457(e)(15); Treas. Reg. §§ 1.457-4(c)(1), 1.457-4(c)(4).
[20] Note that Code § 415(c) does not apply to 457(b) plans, like it may for 403(b) or 401(k) plans.
[21] Code § 414(v)(2).
[22] Treas. Reg. §§ 1.457-4(c)(2); 1.457-4(c)(4); Code § 414(v).}

This publication is intended for general information purposes only and does not and is not intended to constitute legal advice. The reader should consult with legal counsel to determine how laws or decisions discussed herein apply to the reader's specific circumstances.