Annual FSA Contribution Limits

Health flexible spending arrangements (FSAs) offer tax-advantaged reimbursement for qualifying medical expenses. The IRS sets limits on the amount individuals can benefit from this arrangement on a tax-favored basis. Additionally, FSAs are subject to various rules about annual contribution and reimbursement limits, which can often lead to confusion. Below are the details regarding how these annual FSA contribution and reimbursement limits apply.

Health FSAs - Plan Year Contribution Limits

The health FSA salary reduction limit (e.g., $3,400 for 2026) applies on a plan year basis. For example, a health FSA with an April – March plan year could allow employees to elect to contribute up to $3,400 for the April 2026 – March 2027 plan year. The limit applies to employee contributions, so employers could contribute in addition to the 2026 $3,400 contribution limit (subject to excepted benefit rules, which limit employer contributions to the greater of $500 or a match of the employee’s contributions).

The limit applies per employee, not on a household basis, so if both spouses are employed and eligible for health FSA coverage, each spouse could contribute up to $3,400 for 2026. In addition, the limit applies on a per-employer basis, so an employee who works for two unrelated employers (i.e., not part of a controlled group or affiliated service group), whether simultaneously or at different times during the same plan year, may elect up to $3,400 in 2026 under each employer’s health FSA.

For a short plan year, the employer is required to pro-rate the annual contribution limit (e.g., ½ of the annual limit for a 6-month short plan year). However, an employee who joins a health FSA mid-plan year may elect to make up to the full annual contribution limit ($3,400 for 2026). This is true even if the individual contributed to a health FSA under another unrelated employer’s plan during the same year.

Example:

Denise is hired by Employer A on May 6, 2026. Employer A offers a health FSA that runs on a calendar year. Denise elects to contribute $3,400 to the health FSA starting June 1, 2026. Denise is permitted to make the full annual election even though she is joining mid-plan year. She will be able to make contributions of $485.71/month to her health FSA for 7 months of coverage, and due to the “uniform contribution rule,” Denise’s full annual contribution election amount is available for reimbursement of claims beginning on June 1.

If you have questions, please contact your North Risk Partners Risk Advisor. Don’t have an advisor? No problem. We’ll help you find one.

This legal update is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.