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Comp and Benefits Brief

Professionals seating in a conference room

Nov. 15, 2024

2025 Cost-of-Living Adjustments for Benefit Plans

By Elaine Yap, Ann E. Murray, Susan E. Stoffer

The IRS has released the 2025 cost-of-living adjustments to certain limits, thresholds and penalties that apply to employee benefits plans and programs. While most retirement plan limits and thresholds increased, there were a few reductions to limits and penalties under the Affordable Care Act. Please see below for a breakdown of these changes.

Qualified Retirement Plan Changes for 2025[1]

 

Provision

2025

2024

Change?

401(k)/403(b) Plans

Annual Limit on Deferrals

$23,500

$23,000

Yes

Annual Catch-up Limit, 50 years or older

$7,500

$7,500

No

Annual Catch-up Limit, Age 60-63

$11,250

$7,500

Yes

Annual Limit on Contributions (DC Plans)

$70,000

$69,000

Yes

General Limits & Thresholds

HCE Prior Year Compensation Threshold

$160,000

$155,000

Yes

Key Employee Compensation Threshold

$230,000

$220,000

Yes

Annual Compensation Limit

$350,000

$345,000

Yes

ESOP Limits

Amount Balance Limit Subject to 5-Year Distribution Period

$1,415,000

$1,380,000

Yes

Incremental Amount Adding Additional Year(s) to 5-Year Distribution Period

$285,000

$275,000

Yes

Maximum Withdrawal Amounts

Domestic Abuse Distribution

$10,300

$10,000

Yes

Withdrawal for Emergency Expenses

$1,000

$1,000

No

Defined Benefit Plans

Annual Benefit Limit

$280,000

$275,000

Yes

 

PBGC Premiums for Defined Benefit Pension Plans for 2025

 

Premium

2025

2024

Change?

Single Employer Plans

Flat Rate (Per Participant)

$106

$101

Yes

Variable Rate for $1,000 of Unfunded Vested Benefits

 

$52

 

$52

 

No

Per Participant Variable Cap

$717

$686

Yes

Multiemployer Plans (e.g., union)

Flat Rate (Per Participant)

$39

$37

Yes

 

Deferred Compensation Limit Changes for 2025

 

Provision

2025

2024

Change?

457(b) Plans

Annual Limit on Contributions

$23,500

$23,000

Yes

Annual Catch-up Limit

$7,500

$7,500

No

409A Deferred Compensation

Specified Employee Compensation Threshold

$230,000

$220,000

Yes

Involuntary Separation Pay Limit

$700,000

$690,000

Yes

 

Health and Welfare Plan Changes for 2025

 

Limitation

2025

2024

Change?

HDHP & HSA Limits

 

Annual Deductible – Minimum

$1,650/$3,300

$1,600/$3,200

Yes

Out-of-Pocket Expenses (HSA) – Maximum

$8,300/$16,600

$8,050/$16,100

Yes

HSA Contribution Limit (Individual/Family)

$4,300/$8,550

$4,150/$8,300

Yes

Catch-Up Limit

$1,000

$1,000

No

Flexible Spending Account (FSA)

Health FSA – Employee Contribution Limit

$3,300

$3,200

Yes

Health FSA – Maximum Carryover

$660

$640

Yes

Dependent Care FSA – Employee

Contribution Limit

$5,000 married filing jointly or single

 

$2,500 married filing separately

$5,000 married filing jointly or single

 

$2,500 married filing separately

No

 

Affordable Care Act (ACA) Changes for 2025

 

Provision

2025

2024

Change?

ACA Limits for Non-Grandfathered Health Plans

Out-of-Pocket Maximum  (Individual/Family)

$9,200/$18,400

$9,450/$18,900

Yes

Embedded Individual Maximum within Family Coverage

$9,200

$9,450

Yes

Affordability

9.02%

8.39%

Yes

Penalties

No Offer of Coverage (Penalty A)

$2,900

$2,970

Yes

Coverage Fails Minimum Value or Affordability

$4,350

$4,460

Yes

 

If you have questions regarding these changes, please contact any member of the Nelson Mullins Employee Benefits and Executive Compensation Group or the Nelson Mullins attorney with whom you work.


[1] Additional changes apply to SEPs and SIMPLEs that are not addressed in this alert.