The IRS released Rev. Proc. 2025-19 on May 1, 2025, containing the 2026 high deductible health plan (HDHP) and health savings account (HSA) annual limits. The U.S. Department of Health and Human Services also previously released the 2026 annual limits for non-grandfathered medical plans subject to the Affordable Care Act (ACA). These separate ACA limits generally apply only to non-HDHPs, with a limited exception addressed later in our alert.
This alert reflects both the applicable 2025 and 2026 limits for comparison purposes and is relevant for all employers offering health coverage to their employees.
The annual IRS adjustments to the ACA’s employer shared responsibility penalties and the affordability safe harbor percentage will appear later this year. The 2026 annual limits for health care flexible spending accounts, qualified transportation fringe benefits, and adoption assistance programs will also appear later this year (typically during the fourth quarter). We will publish updates when this information becomes available.
