June 2025
Stephanie Hall, Associate Director, Benefits Compliance
The Internal Revenue Service (“IRS”) is required to announce annual inflation-adjusted limits for health savings accounts (“HSAs”), high deductible health plans (“HDHPs”) and excepted benefit health reimbursement arrangements (“EBHRAs”) by June 1. To that end, the IRS issued Revenue Procedure 2025-19 on May 1, 2025, providing updated limits for plan years commencing on or after January 1, 2026.
Employer Action Items
- Employer plan sponsors should review the updated limits set out below relative to their plan and program designs, updating as necessary or required to comply with the annual inflation adjustments recently announced by the IRS.
- Employer plan sponsors should also plan to review and update any required participant disclosures, as well as their benefit guides and program brochures, to reflect the adjusted amounts.
- Employer plan sponsors will need to also work with support administrators and insurance issuers in the adoption and implementation of the adjusted annual limits.
Summary
On May 1, 2025, the IRS released Rev. Proc. 2025-19 to provide the inflation-adjusted limits for HSAs and HDHPs for 2026, as reflected in the table provided below.
| Coverage Type | HSA Contribution Limit 2025 | HSA Contribution Limit 2026 | HDHP Minimum Deductible 2025 | HDHP Minimum Deductible 2026 | HDHP Max Out-of-Pocket 2025 | HDHP Max Out-of-Pocket 2026 |
|---|---|---|---|---|---|---|
| Self-only HDHP | $4,300 | $4,400 | $1,650 | $1,700 | $8,300 | $8,500 |
| Family HDHP | $8,550 | $8,750 | $3,300 | $3,400 | $16,600 | $17,000 |
| Catch-up Contribution (age 55+) | $1,000 | $1,000 | N/A | N/A | N/A | N/A |
In addition, Rev. Proc. 2025-19 included inflation-adjusted limits for EBHRAs for plan years beginning on or after January 1, 2026. This amount was increased to $2,200 (up from $2,150) for plan years beginning in 2025. As a refresher, EBHRAs are a type of tax-advantaged health reimbursement arrangement that is funded by the employer and that can be utilized as a cost-sharing supplement to an employer’s traditional group health plan. EBHRAs are subject to several qualification requirements, one of which is the requirement that the total annual benefit maximum not exceed the annually adjusted limit (note that carryover amounts are disregarded for these purposes).
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