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Worksheet 6A rarely trips people on the math. It trips them on the numbers printed on the page, because the 4-2023 revision still shows 2022 values, a §415(c) limit of $61,000 and a §401(a)(17) limit of $305,000, and a reviewer who tests against those is testing against the wrong year. Refresh the figures against the current IRS COLA notice before you start, every time.
Form 15417-D is IRS Worksheet 6A, the Employee Plans worksheet plan sponsors and IRS reviewers use to confirm a 403(b) plan document meets the contribution and compensation limits. For 2025 those are a §415(c) annual additions limit of $70,000, a §402(g) elective deferral limit of $23,500, and a §401(a)(17) compensation limit of $350,000, with a $7,500 age-50 catch-up and an $11,250 enhanced catch-up at ages 60 to 63. Each item is answered Yes, No, or N/A, and any No has to be explained on the worksheet.
Key Takeaways
- Form 15417-D is IRS Worksheet 6A – an Employee Plans worksheet (catalog number 94032O, revised April 2023) used by plan sponsors and IRS reviewers to evaluate whether a 403(b) plan document satisfies the contribution and benefit limits under IRC §415, §402(g), and §401(a)(17).
- Who uses it: Plan sponsors, third-party administrators, and IRS Employee Plans reviewers during 403(b) plan determination and audit review – participants do not file or submit this form with their personal tax returns.
- Four sections across three pages: Section I (Definitions), Section II (Limits on Elective Deferrals), Section III (Limitations on Annual Additions under §415), and Section IV (§401(a)(17) Compensation Limit).
- 2025 dollar limits (per IRS Notice 2024-80): §415(c) annual additions limit of $70,000, §402(g) elective deferral limit of $23,500, age 50 catch-up of $7,500, SECURE 2.0 age 60-63 enhanced catch-up of $11,250, and §401(a)(17) compensation limit of $350,000.
- Stale printed values: The 4-2023 revision prints 2022 values – §415(c) of $61,000 and §401(a)(17) of $305,000. Refresh against the current IRS COLA notice before each plan-year review.
- Yes / No / N/A responses: Each worksheet item is answered Yes, No, or N/A. Any “No” answer must be explained in the space provided on the worksheet.
What Form 15417-D Is and When to Use It
Form 15417-D, “403(b) Plan Limitation on Contribution and Benefits,” is the IRS Employee Plans Worksheet 6A used to evaluate a 403(b) plan’s compliance with the contribution and benefit limits of IRC §415, §402(g), and §401(a)(17). The form is issued by the Department of the Treasury – Internal Revenue Service (catalog number 94032O, revision date April 2023). It is an internal review worksheet, not a return.
The worksheet has four sections across three pages: Section I (Definitions), Section II (Limits on Elective Deferrals), Section III (Limitations on Annual Additions under §415), and Section IV (§401(a)(17) Compensation Limit). Each item is answered Yes, No, or N/A. A “Yes” indicates a favorable conclusion is warranted; a “No” indicates a problem; and any “No” answer must be explained in the space provided on the worksheet.
The technical principles in the worksheet may be changed by future regulations or IRS guidelines. The dollar amounts printed on the 4-2023 revision reflect 2022 cost-of-living values and must be refreshed against the current IRS COLA notice each plan year – Section III (§415(c) annual additions) and Section IV (§401(a)(17) compensation) are the items most affected.
When the Worksheet Is Used
Form 15417-D is used during 403(b) plan determination and during IRS Employee Plans examinations. Plan sponsors and third-party administrators also use it as an internal compliance checklist when adopting or restating a plan document, and at each annual COLA refresh under IRC §415(d) to confirm the plan’s limitation language matches the current dollar limits. If the plan does not offer elective deferrals, Section II is skipped entirely and the reviewer proceeds to Section III.
Who Completes the Worksheet
The worksheet is completed by the plan sponsor, the third-party administrator working on the sponsor’s behalf, or the IRS Employee Plans reviewer. Participants do not sign or submit Form 15417-D – it is not attached to any individual’s tax return. Each Section I through IV item is answered against the plan document’s actual language, with the supporting plan reference recorded in the “Plan Reference” column.
How to Complete Form 15417-D
The worksheet covers four substantive sections across three pages. For each item, the reviewer marks one of three responses – Yes, No, or N/A – against the plan-document language being reviewed and records the plan reference in the “Plan Reference” column.
| Section | What It Covers | Practitioner Tip |
|---|---|---|
| Section I – Definitions | Limitation year (Treas. Reg. §1.415(j)-1), Includible Compensation (Treas. Reg. §1.403(b)-2(b)(11)), Year of Service, church-employee aggregation | Confirm the plan defines “Year of Service” with fractional credit for part-time work and applies the five-year deemed Includible Compensation rule for former employees |
| Section II – Limits on Elective Deferrals | §402(g)(1)(B) deferral limit, cross-plan aggregation, age 50 catch-up, special 403(b) 15-year catch-up, catch-up allocation order | If the plan does not offer elective deferrals, skip to Section III. Excess amounts allocate first to the special 403(b) 15-year catch-up, then to the age 50 catch-up |
| Section III – Limitations on Annual Additions | §415(c) lesser-of test (dollar limit or 100% of Includible Compensation), excess contribution segregation, controlled-employer aggregation | Refresh the printed 2022 dollar amount ($61,000) to the current notice value ($70,000 for 2025) before reviewing Section III.b |
| Section IV – §401(a)(17) Compensation Limit | Compensation cap on contributions ($350,000 for 2025), church and QCCO exemption, elective deferral exemption | The §401(a)(17) cap applies to employer or nonelective contributions only – not to elective deferrals, and not to churches or QCCOs |
| Yes / No / N/A and explanation | Each item gets Yes, No, or N/A; every “No” answer requires a written explanation on the worksheet | Document the explanation alongside the plan-document language relied on so the answer can be reproduced at the next review cycle |
Where the Completed Worksheet Goes
The completed Form 15417-D is retained in the plan sponsor’s plan-document file and used during IRS Employee Plans determinations and examinations. It is not filed with the IRS as a return and is not attached to any participant’s individual tax return. The worksheet’s value is in the documentation trail it creates – the plan-document language reviewed, the answer given, and the explanation supporting any “No” answer.
Section I – Definitions in Detail
Section I checks that the plan defines the foundational terms the limitation tests later in the worksheet rely on. Each definition has to track the Code and the Treasury regulation it points to. A plan that uses a looser definition will produce wrong answers downstream in Sections II, III, and IV.
Limitation Year and Includible Compensation
The plan must define the limitation year in accordance with Treas. Reg. §1.415(j)-1, and define compensation as “Includible Compensation” per Treas. Reg. §1.403(b)-2(b)(11), with that definition used for §415 limit purposes. For self-employed ministers, Includible Compensation is earned income under IRC §401(c)(2). Differential wage payments and difficulty-of-care payments must be treated as compensation under IRC §415(c)(3), and the post-severance compensation rules in Treas. Reg. §1.415(c)-2(e) also apply to 403(b) plans.
Year of Service and Former Employees
The plan must define “Year of Service” as each full year of full-time work for an eligible employer for the entire work period, plus fractional credit for part-time work. A former employee is deemed to have Includible Compensation for the next five taxable years after ceasing employment – contributions cannot continue indefinitely. For church employees, years of service under Treas. Reg. §1.403(b)-4(e) must aggregate periods of employment across the eligible employer and any associated church-related organizations.
What the Yes / No / N/A Answers Mean
Each Section I item asks a specific question about the plan’s limitation language. A “Yes” means the plan satisfies the requirement; a “No” means there is a problem; “N/A” means the item does not apply (for example, a non-church plan answering N/A on the church-related aggregation item). Any “No” in Sections I through IV must be explained on the worksheet.
Section II – Limits on Elective Deferrals
Section II walks the plan document through the §402(g) elective deferral limit, the cross-plan aggregation rule, the age 50 catch-up, and the special 403(b) 15-year catch-up. If the plan does not offer elective deferrals, Section II is skipped entirely and the reviewer moves to Section III.
The §402(g) Elective Deferral Limit
Elective deferrals must not exceed the limit imposed by IRC §402(g)(1)(B) (cost-of-living adjusted under §402(g)(4)) – $23,500 for 2025 per IRS Notice 2024-80. The limit aggregates across all the participant’s §402(g)-eligible plans, including any 401(k), other 403(b), SARSEP, or SIMPLE. Treating the 403(b) in isolation misses cross-plan excess deferrals.
Age 50 Catch-Up
The age 50 catch-up ($7,500 for 2025) is optional, but if the plan permits it the plan document must explicitly say so. SECURE 2.0 §109 adds an enhanced catch-up for participants aged 60 through 63 equal to the greater of $10,000 or 150% of the regular catch-up – $11,250 for 2025.
Special 403(b) 15-Year Catch-Up
The special 403(b) 15-year catch-up is optional and available only to a “qualified organization” defined in IRC §402(g)(7)(B). A qualified employee must have at least 15 years of service with the qualified organization. The catch-up is capped at $3,000 per year and $15,000 over a participant’s lifetime. For church-related organizations, all entities controlled by a church-related organization under IRC §414(e)(3)(B)(ii) must be treated as a single employer when calculating years of service and prior special-catch-up usage.
Catch-Up Allocation Order
When both the age 50 catch-up and the special 403(b) 15-year catch-up are available, amounts above the §402(g) limit must be allocated first to the special 403(b) 15-year catch-up and then to the age 50 catch-up. Applying age 50 first incorrectly reduces the lifetime $15,000 special catch-up capacity.
Section III – Limitations on Annual Additions
Section III applies the §415 limit on annual additions to a defined contribution plan. The cap binds even when the §402(g) deferral limit is satisfied, and the dollar piece of the cap changes every year under the §415(d) COLA.
The Lesser-Of Rule
Annual additions for any limitation year cannot exceed the lesser of the §415(c) dollar limit ($70,000 for 2025, per IRS Notice 2024-80; the 4-2023 form prints the 2022 value of $61,000) or 100% of the participant’s Includible Compensation for the limitation year. For participants with low Includible Compensation, the 100% cap binds well before the dollar limit – applying only the dollar limit produces over-contributions.
Excess Annual Additions
Any excess annual additions must be held in a separate account under the IRC §403(b) contract – an account that is not treated as a 403(b) contract – until distributed. Leaving the excess in the 403(b) account gives it tax-deferred treatment it is not entitled to.
Annuity Contract and Controlled-Employer Aggregation
All 403(b) annuity contracts purchased by an employer for a participant are treated as one 403(b) annuity contract for purposes of §415 limits on annual additions. If the participant controls any employer, annual additions across all 403(b) plans of the employer, any defined contribution plans of controlled employers, and any 403(b) plans of any other employers must be aggregated against a single annual-additions limit.
Section IV – §401(a)(17) Compensation Limit
Section IV checks that the plan applies the §401(a)(17) cap on the amount of compensation used to calculate contributions. Like §415(c), the limit is cost-of-living adjusted every year and the 4-2023 form prints the stale 2022 value.
The Compensation Cap
The plan must limit compensation taken into consideration in determining contributions to the §401(a)(17) cost-of-living adjusted amount – $350,000 for 2025 per IRS Notice 2024-80 (the form prints $305,000 for 2022). The cap controls how much of a high earner’s compensation can be used as the base for employer and nonelective contribution calculations.
Where the Limit Does Not Apply
The §401(a)(17) limit does not apply to elective deferrals – those are governed by §402(g). It also does not apply to churches or qualified church-controlled organizations (QCCOs). Applying the cap to elective deferrals inappropriately reduces deferral capacity for high earners; applying it to church or QCCO employees unnecessarily restricts church-plan contributions.
Why the Refresh Matters
The 2022 value ($305,000) printed on the worksheet is stale on day one of every plan year after 2022. The reviewer must pull the current COLA-adjusted amount from the latest IRS Notice (Notice 2024-80 for 2025) and overwrite the printed value before answering Section IV.a. Carrying the printed number into a 2025 review understates the cap and can cause downstream contribution errors.
Where Form 15417-D Fits in the IRS Employee Plans Worksheet Series
Form 15417-D is part of the IRS Employee Plans worksheet series used during retirement-plan determinations. Within that series, it is designated “Worksheet 6A – Determination of 403(b) Status,” with catalog number 94032O and revision date April 2023. The worksheet’s scope is the limitation and benefit rules a 403(b) plan must satisfy under IRC §415, §402(g), and §401(a)(17).
What the Worksheet Covers and What It Does Not
The worksheet evaluates plan-document compliance with the contribution and benefit limit rules. It does not evaluate plan-document compliance with non-discrimination testing, vesting, distribution rules, top-heavy testing, or other 403(b) requirements that fall outside the §415 / §402(g) / §401(a)(17) scope. Reviewers needing those checks use the corresponding worksheets in the IRS Employee Plans determination series.
Pairing with Related Determination Tools
In a typical 403(b) plan determination or examination, Form 15417-D is paired with the plan’s underlying adoption agreement, the latest IRS COLA notice (Notice 2024-80 for 2025), and the participant-level census used to validate the answers in Sections II and III. The worksheet itself does not capture participant-level data – it confirms the plan’s limitation language – so the census is the bridge between the document review and the operational test.
Common Mistakes That Slow Things Down
From my side of the desk, the same five 403(b) limit traps show up every plan-determination cycle. Each one traces back to a misreading of the §415, §402(g), or §401(a)(17) rules that Form 15417-D is designed to surface.
Practical Checklists You Can Reuse
These checklists are copy-paste ready for firm SOPs. Use them at the November COLA refresh, at plan adoption, and during any IRS Employee Plans review cycle.
Annual COLA refresh (2025 plan year)
- Update the §415(c) annual additions dollar limit to $70,000 (replaces the $61,000 printed on the 4-2023 revision).
- Update Section II.a with the §402(g)(1)(B) elective deferral limit of $23,500.
- Confirm the age 50 catch-up of $7,500 is reflected in Section II.c (per IRS Notice 2024-80).
- Add the SECURE 2.0 §109 enhanced catch-up of $11,250 for participants aged 60-63 to the Section II review.
- Update Section IV.a with the §401(a)(17) compensation limit of $350,000.
- Confirm the special 403(b) 15-year catch-up annual cap of $3,000 and lifetime cap of $15,000 are unchanged.
- Re-walk every Section I-IV answer against the refreshed numbers before sign-off.
Plan-document compliance check (Sections I through IV)
- Confirm Section I.a uses the limitation year defined per Treas. Reg. §1.415(j)-1.
- Confirm Section I.b uses the Includible Compensation definition under Treas. Reg. §1.403(b)-2(b)(11).
- Confirm Section I.b treats differential wage payments and difficulty-of-care payments as compensation under IRC §415(c)(3).
- Confirm the five-year deemed Includible Compensation rule for former employees is documented in Section I.
- Confirm Section II.b applies the §402(g) limit in aggregate across all the participant's §402(g)-eligible plans.
- Confirm Section III.b applies the lesser of the §415(c) dollar limit or 100% of Includible Compensation.
- Confirm Section III.f aggregates all 403(b) annuity contracts of the employer as one contract under IRC §415.
- Document an explanation for every "No" answer in Sections I-IV in the space provided on the worksheet.
Excess annual addition segregation
- Flag any annual addition above the lesser of $70,000 or 100% of Includible Compensation as an excess.
- Segregate the excess into a separate account that is not treated as a 403(b) contract until distributed.
- Confirm the plan document includes the required segregation language for excess annual additions.
- Document any controlled-employer aggregation under Section III.f when the participant controls another employer.
- Route the excess treatment through Accountably's plan-compliance workflow for review continuity.
Keep 15417-D Season From Stalling
403(b) plan determinations move on a tight annual calendar. The IRS cost-of-living adjustments under IRC §415(d) reset the §415(c) dollar limit, the §402(g) elective deferral cap, and the §401(a)(17) compensation cap every November – the 2025 values arrived through IRS Notice 2024-80 – which means every Section II, III, and IV answer on Form 15417-D (4-2023) is stale on day one of the new plan year.
The work that slows the cycle is not the individual limit lookup. It is reconciling each updated number back to plan-document language across multiple 403(b) sponsors, then catching the carry-forward errors before an IRS Employee Plans reviewer does. Treating Form 15417-D as a living checklist refreshed each plan year against the current notice is what keeps the determination cycle moving.
- Refresh the §415(c) annual additions limit to the current notice value ($70,000 for 2025) before reviewing Section III.b.
- Update Section II.a with the current §402(g) elective deferral limit ($23,500 for 2025) and add the SECURE 2.0 §109 enhanced catch-up of $11,250 for participants aged 60-63.
- Verify the catch-up allocation order on Section II.d: special 403(b) 15-year catch-up first, age 50 catch-up second, not the other way around.
- Update Section IV.a with the current §401(a)(17) compensation cap ($350,000 for 2025) and confirm the church and QCCO exemption is correctly applied for those sponsors.
- Document every "No" answer in Sections I-IV with the required explanation before the plan sponsor signs.
Plan sponsors and the firms advising them rely on Accountably's structured tax and compliance support to keep each year's Form 15417-D refresh on a documented cadence, with the IRS Notice values verified once and propagated across every sponsor file.
FAQs
What is Form 15417-D used for?
Form 15417-D is IRS Worksheet 6A, used during 403(b) plan determination and audit review to confirm a 403(b) plan document satisfies the contribution and benefit limits under IRC §415, §402(g), and §401(a)(17). Plan sponsors, third-party administrators, and IRS Employee Plans reviewers complete it; participants do not file or submit it with their personal returns.
What 2025 dollar limits should I use when reviewing a plan against Form 15417-D?
For 2025, per IRS Notice 2024-80, the §415(c) annual additions dollar limit is $70,000, the §402(g) elective deferral limit is $23,500, the age 50 catch-up is $7,500, the SECURE 2.0 enhanced catch-up for participants aged 60-63 is $11,250, and the §401(a)(17) compensation limit is $350,000. The form itself prints the 2022 values ($61,000 and $305,000) and must be refreshed each plan year before answering Sections III and IV.
How is the special 403(b) 15-year catch-up coordinated with the age 50 catch-up?
When both catch-ups are available, amounts above the §402(g) limit must be allocated first to the special 403(b) 15-year catch-up and second to the age 50 catch-up. The special 403(b) catch-up has a $3,000 annual maximum and a $15,000 lifetime maximum per IRC §402(g)(7), and is available only to qualified organizations defined in §402(g)(7)(B). Reversing the order overstates the age 50 amount and understates remaining 15-year capacity.
Does the §401(a)(17) compensation limit apply to elective deferrals?
No. Section IV of Form 15417-D notes that the §401(a)(17) compensation limit ($350,000 for 2025) does not apply to elective deferrals and does not apply to churches or qualified church-controlled organizations (QCCOs). The cap applies to employer or nonelective contribution calculations only.
How are excess annual additions handled under Form 15417-D?
Section III of Form 15417-D requires excess annual additions to a 403(b) contract to be held in a separate account under the IRC §403(b) contract – an account that is not treated as a 403(b) contract – until distributed. Plans cannot leave the excess in the 403(b) account; doing so gives the excess tax-deferred treatment it is not entitled to.