Table of 2026 Indexed Benefit Limits
Aug 11, 2025
2026 indexed benefit limits we have seen published so far.
We updated each number below as figures are released throughout the year. HSAs are typically announced in May, affordability is typically announced in August, a host of other limits are typically announced in October, and the FPL for non-calendar year plans is released mid-January 2026.
Affordable Care Act (ACA)
| 2024 | 2025 | 2026 | |
|---|---|---|---|
| • Affordability % • Single FPL for 1/1 plan • Single PFL for non-CY plan | • 8.39% • $101.93/mo • $105.29/mo | • 9.02% • $113.20/mo • $117.63/mo | • 9.96% • $129.90/mo • TBD |
| • §4980H(a) penalty • Per month | • $2,970/yr • $247.50/mo | • $2,900/yr • $241.67/mo | • $3,340/yr • $278.33/mo |
| • §4980H(b) penalty • Per month | • $4,460/yr • $371.67/mo | • $4,350/yr • $362.50/mo | • $5,010/yr • $417.50/mo |
| • Non-grandfathered (non-GF) max out-of-pocket (OOP) | • Per person $9,450/yr • Family $18,900/yr | • Per person $9,200/yr • Family $18,400/yr | Per person $10,600/yr • Family $21,200/yr |
| • Patient Centered Outcomes Research (PCOR) fee (payable by employers with health reimbursement arrangement (HRA) or self-funded health plan) | For PCOR fee due Wednesday 7/31/24 • $3.00 pppy for plan year ending 1/1/23 – 9/30/23 • $3.22 pppy for plan year ending 10/1/23 – 12/31/23 | For PCOR fee due Thursday 7/31/25 • $3.22 pppy for plan year ending 1/1/24 – 9/30/24 • $3.47 pppy for plan year ending 10/1/24 – 12/31/24 | For PCOR fee due Thursday 7/31/26 • $3.47 pppy for plan year ending 1/1/25 – 9/30/25 • TBD pppy for plan year ending 10/1/25 – 12/31/25 |
Health and/or Limited Purpose Flexible Spending Account (FSA)
| 2024 | 2025 | 2026 | |
|---|---|---|---|
| • Max paycheck deductions (employer may also contribute greater of $500 or 1:1 match) | • $3,200/yr | • $3,300/yr | • $3,300/yr |
| • Max carryover to a plan starting the next CY | • $640 to a 2025 plan | • $660 to a 2026 plan | • TBD |
Dependent Care FSA
| 2024 | 2025 | 2026 | |
|---|---|---|---|
| • Max contribution (includes both employer and employee funds; might need to pro-rate down for partial year eligibility) | • $5,000/yr • $2,500/yr if married filing separately | • $5,000/yr • $2,500/yr if married filing separately | • $7,500/yr • $3,750/yr if married filing separately |
Health Savings Account (HSA)
| 2024 | 2025 | 2026 | |
|---|---|---|---|
| • Max contribution (includes both employer and employee funds; might need to pro-rate down for partial year eligibility) | • Single $4,150/yr • Family $8,300/yr | • Single $4,300/yr • Family $8,550/yr | • Single $4,400/yr • Family $8,750/yr |
| • Catch-up contribution (per HSA account holder age 55+ on 12/31 that year; never indexes) | • $1,000/yr | • $1,000/yr | • $1,000/yr |
| HDHP minimum deductible | • Single $1,600/yr • Family $3,200/yrI (If non-single coverage offers an embedded per-person deductible, must set that to at least $3,200) | • Single $1,650/yr • Family $3,300/yr (If non-single coverage offers an embedded per-person deductible, must set that to at least $3,300) | • Single $1,700/yr • Family $3,400/yr If non-single coverage offers an embedded per-person deductible, must set that to at least $3,300) |
| • HDHP max OOP (if non-GF, note family per-person OOP limit) | • Single $8,050/yr • Family $16,100/yr • Non-GF $9,450 per person | • Single $8,300/yr • Family $16,600/yr • Non-GF $9,200 per person | • Single $8,500/yr • Family $17,000/yr • Non-GF TBD |
§ 132 Qualified Commuter Plan
| 2024 | 2025 | 2026 | |
|---|---|---|---|
| • Qualified parking • Transit passes and vanpools | • $315/mo • $315/mo | • $325/mo • $325/mo | TBD |
Non-Discrimination Testing
| 2024 | 2025 | 2026 | |
|---|---|---|---|
| • Highly compensated employee (HCE) | • $155,000 | • $160,000 | TBD |
| • Key employee | • $220,000 | • $230,000 | TBD |
Other Plans
| 2024 | 2025 | 2026 | |
|---|---|---|---|
| • Excepted benefit HRA • Qualified small employer HRA • Adoption assistance §137 • Education assistance §127 (*can include student loans 2020 through end of 2025) | • $2,100 • $6,150 single • $12,450 family • $16,810 • $5,250* | • $2,150 • $6,350 single • $12,800 family • $17,280 • $5,250* | TBD |
IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information. This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.
