Recently, the IRS released Rev. Proc. 2025-19, which outlines the adjusted amounts for health saving accounts (HSAs) and high deductible health plans (HDHPs) for the 2026 calendar year. The new limits are summarized in the table below.
| 2026 | 2025 | Change | |
| Annual HSA Contribution Limit (employer and employee) | Self-only: $4,400 Family: $8,750 | Self-only: $4,300 Family: $8,550 | Self-only: +$100 Family: +$200 |
| HSA Catch-Up Contribution Limit (age 55 or older) | $1,000 | $1,000 | No change |
| Minimum Annual HDHP Deductible | Self-only: $1,700 Family: $3,400 | Self-only: $1,650 Family: $3,300 | Self-only: +$50 Family: +$100 |
| Maximum Out-of-Pocket Limit for HDHP (deductibles, co-pays & other amounts except premiums) | Self-only: $8,500 Family: $17,000 | Self-only: $8,300 Family: $16,600 | Self-only: +$200 Family: +$400 |
As a reminder, for an HDHP to be qualified for purposes of HSA-eligibility, it must not pay benefits (other than for preventative care) before the minimum required deductible is met for the level of coverage in which a participant is enrolled. Importantly, plans that provide family coverage with an embedded deductible* must not pay benefits until the minimum required family deductible of $3,400 is met. This means that plans with an embedded deductible must have a self-only deductible that is at least $3,400.
ACA Maximum Out-of-Pocket Limit
The ACA’s out-of-pocket limits for in-network essential health benefits have also been announced and have increased for 2026 (applicable for non-grandfathered group health plans).
| 2026 | 2025 | Change | |
| ACA Maximum Out-of-Pocket Limit | Self-only: $10,150 Family: $20,300 | Self-only: $9,200 Family: $18,400 | Self-only: +$950 Family: +$1,900 |
Note that all non-grandfathered group health plans must contain an embedded individual out-of-pocket limit within family coverage if the family out-of-pocket limit is above $10,150 (for 2026). This is because all non-grandfathered plans (both HDHP and non-HDHP) must cap the out-of-pocket spend at $10,150 for any covered person.
Next Steps for Employers
As employers prepare for the 2026 plan year, they should ensure any plan materials and participant communications reflect the new limits. In addition, with the increase in the HDHP minimum annual deductible, employers should make sure their qualified HDHPs meet the new deductible requirements.
*An embedded deductible allows the plan to pay coinsurance for an individual on family coverage once that individual hits the self-only deductible limit (and once the family deductible is met, coinsurance kicks in for all covered family members).
Additional Resources
The information and materials on this blog are provided for informational purposes only and are not intended to constitute legal or tax advice. Information provided in this blog may not reflect the most current legal developments and may vary by jurisdiction. The content on this blog is for general informational purposes only and does not apply to any particular facts or circumstances. The use of this blog does not in any way establish an attorney-client relationship, nor should any such relationship be implied, and the contents do not constitute legal or tax advice. If you require legal or tax advice, please consult with a licensed attorney or tax professional in your jurisdiction. The contributing authors expressly disclaim all liability to any persons or entities with respect to any action or inaction based on the contents of this blog. © 2025 Sequoia Consulting Group. All Rights Reserved.
