catch-up

We are providing important 2026 informational updates related to the CIRS Plans:

2026 IRS Compensation Limit

• The IRS sets annual limits on the salary that can be used by qualified pension plans such as the CIRS Pension Plan. These limits are applied on a Plan Year basis (July 1 – June 30).  The CIRS Pension Plan automatically applies these limits for all required purposes (benefit amounts, employer contributions, etc.).
• Employers must be mindful of these limits when calculating employee contributions for Tier II Members under the CIRS Pension Plan.
• The compensation limit for the July 1, 2025 to June 30, 2026 Plan Year is $350,000, resulting in a maximum Tier II employee contribution of $10,500 for the current Plan Year.
• For the July 1, 2026 to June 30, 2027 Plan Year, these amounts will increase to $360,000 and $10,800, respectively.

2026 IRS Pre-Tax Contribution Limit

• The IRS sets annual limits on the amount employees can contribute to a 401(k) plan on a Calendar Year basis (January 1 to December 31).
• The 2026 limit for regular 401(k) pre-tax deferrals is $24,500.

2026 Employee Catch-up Contributions

• Employee contribution elections (pre- and post-tax) to the CIRS 401(k) Savings Plan must be made by Members through Voya.
• Members wishing to elect catch-up contributions must complete the attached Catch-up Form and submit it to you as the employer.
• Catch-up contributions are additional pre-tax contributions available to Members who will be age 50 or older by the last day of the calendar year.
• The 2026 catchup limits are:
  • Ages 50-59 by 12/31/2026:         $8,000
  • Ages 60-63 by 12/31/2026:         $11,250
  • Ages 64+ by 12/31/2026:             $8,000

Roth Contributions

• Roth features will be added to the CIRS 401(k) Savings Plan in early 2026.
• The Roth catch-up requirement for Highly Paid Employees (currently those with W-2 compensation over $150,000 in the prior calendar year) was originally scheduled to take effect on 1/1/2024. The IRS delayed implementation to 1/1/2026 and has now issued final regulations stating that, for multiemployer plans (including CIRS), the requirement is further delayed until the expiration of the Collective Bargaining Agreement in effect on 12/31/2025.
• As a result, the Roth catch-up requirement for the CIRS 401(k) Savings Plan will become effective 1/1/2027.
• Additional information regarding Roth contributions and the 2027 catch-up rules will be provided in early 2026.

This information is also available on our website, www.cirsplans.org.

If you have any questions regarding the CIRS Plans, please feel free to call CIRS at 212-674-0101 and ask to speak to a Member Services Representative.

We are providing informational items for the 2025 calendar year related to the CIRS Plans:

2025 IRS Compensation Limits

• The IRS sets annual limits on the salary that can be used by qualified pension plans such as the CIRS Pension Plan. These limits are applied on a plan year basis (July 1 – June 30).  The CIRS Pension Plan already takes these limits into account for all required purposes (benefit amounts, employer contributions, etc.).  However, you as the employer, must be aware of these limits as they apply to the employee contributions for Tier II Members under the CIRS Pension Plan.  The July 1, 2024 to June 30, 2025 compensation limit is $345,000 which means that the maximum Tier II employee pension contribution is $10,350 for the 2024-2025 Plan Year.  These amounts will increase to $350,000 and $10,500 for the 2025-2026 Plan Year.

2025 IRS Pre-Tax Contribution Limits

• The IRS sets annual limits on the amount of pre-tax contributions employees can make to a 401(k) plan.  These limits are applicable on a calendar year basis (January 1 – December 31).  The 2025 limit for regular 401(k) pre-tax deferrals is $23,500.

• NEW Effective 1/1/2025, the law has changed in how catchup limits are structured.  Instead of one flat dollar amount applicable to everyone over age 50, the law now allows for those ages 60-63 to contribute a higher amount.

• The 2025 catchup limits are:
  • Ages 50-59 by 12/31/2025 – $7,500
  • Ages 60-63 by 12/31/2025 – $11,250
  • Ages 64+ by 12/31/2025 – $7,500

2025 Employee Contribution Catch-up Form

• Employee contribution elections (pre and post-tax) to the CIRS 401(k) Savings Plan must be made by Members through Voya.  However, if Members wish to elect catch-up contributions, they must complete the attached Catch-up Form and submit to you (the employer).  Catch-up contributions are additional pre-tax contributions that Members who will be age 50 or older by the last day of the calendar year can make in addition to the IRS regular pre-tax contributions.

If you have any questions regarding the CIRS Plans, please feel free to call CIRS at 212-674-0101 and ask to speak to a Member Services Representative.