New York Employer Guide · Last reviewed May 2026

Section 125 Plans for New York Employers — 2026 Guide

By David Newman · Referral Partner, Section 125 Savings · San Pedro, CA

New York employers benefit from Section 125 with both federal AND New York state income tax savings. NY honors federal IRC § 125 pre-tax reductions for state income tax purposes — meaning the pre-tax reduction reduces both federal and NY taxable wages. For employees in higher NY brackets (6.85-10.9%), this adds meaningful additional state-tax savings on top of the federal FICA savings.

New York's industry mix — finance + healthcare + hospitality + construction trades + retail — maps to a wide range of Section 125-eligible operations. The structure works for a mid-sized hospitality operator in Manhattan as cleanly as for a healthcare network in upstate NY.

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New York-specific Section 125 considerations

New York state income tax treatment

NY honors federal Section 125 pre-tax reductions for state income tax. The pre-tax reduction reduces both federal and NY taxable wages. NY's progressive bracket structure means higher-earning employees see larger state-tax savings on top of the federal FICA savings.

New York Paid Family Leave (PFL)

NY PFL is funded via employee payroll deduction. PFL contributions are calculated on taxable wages. Section 125 pre-tax reductions reduce PFL-taxable wages slightly, marginally reducing the employee's PFL contribution. Employee-side savings layer.

New York Workers' Comp specifics

New York uses NYCIRB classifications with state-specific rate filings. Section 125 reductions to taxable payroll reduce the WC premium base. NY's WC environment includes specific construction-industry rules (Workers' Comp Reform Act provisions) — coordinate with your NY WC broker for the audit-cycle calculation.

NYC-specific local taxes

New York City employees pay NYC local income tax on wages. Section 125 pre-tax reductions also reduce NYC taxable wages, slightly reducing NYC-employee tax burden. Functionally a small additional savings layer for NYC employees.

New York industry concentrations

The largest W-2 employer concentrations in New York where Section 125 economics work strongest:

  • Finance + insurance (NYC concentration)
  • Healthcare networks (NY-Presbyterian, Mount Sinai, etc.)
  • Hospitality + restaurants (NYC + upstate tourism)
  • Construction trades
  • Retail
  • Higher education + nonprofit (large W-2 employer category)

Each industry has its own Workers' Comp classification rate. The Section 125 FICA reduction is mechanical at $681.60/W-2 employee/year regardless of industry; the WC reduction layer scales with classification rate.

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Darcy L. Hitesman, J.D.

HitesmanLaw P.A. · Minneapolis, MN

35+ years as an Employee Benefits attorney specializing in IRC Section 125, ERISA, HIPAA, and the ACA. Her May 5, 2025 opinion letter concludes: “In this firm's opinion, the Program described satisfies applicable IRS requirements.”

She specifically reviewed the IRS Chief Counsel Advice memoranda on "double-dip" arrangements — the exact schemes the IRS has flagged — and concluded this program is built differently and compliantly.

Named a Super Lawyer every year since 2000. AV-rated (highest possible rating) in Martindale-Hubbell since 1998.
Co-author: ERISA Compliance for Health & Welfare Plans (Thomson Reuters/EBIA) — the national compliance standard manual since 1999.
Member, Technical Advisory Group — Employers Council on Flexible Compensation. She helps set the industry standards for Section 125 plans nationally.

CBIZ Advisors LLC

Top-7 U.S. Accounting Firm · Cleveland, OH · 135,000+ Clients

CBIZ independently reviewed the program against IRC §§ 125, 105, and 106, plus ERISA, ACA, and COBRA requirements. Their August 22, 2025 letter concludes: “If operated per its provisions, the Program appears to satisfy the requirements of ERISA, the ACA, and COBRA as well.”

This review was commissioned by Affinity Hospice's CEO before enrolling his nationwide organization — and the CFO (himself a CPA) shared the letter publicly in his testimonial.

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Direct From the U.S. Government

Section 125 has been in the Internal Revenue Code since 1978. Congress wrote it there specifically to encourage employers to fund preventive healthcare for American workers. This is not a loophole — it is the precise, intended use of a 47-year-old federal law, grounded in IRS Revenue Ruling 69-154, the specific published ruling supporting the benefit payment structure.

→ Verify on IRS.gov — Section 125 Cafeteria Plans ↗
New York Section 125 FAQ

Common New York-specific questions

Section 125 reduces taxable wages but doesn't change gross wages or wage statements (paystubs continue to show gross wages and the new pre-tax deduction line). Wage Theft Prevention Act compliance is unaffected.
NYC public sector follows separate cafeteria plan rules with NYC-specific implementation details. Most NYC public sector entities have their own established cafeteria plan structures. The Preventive Care variant is generally aimed at private-sector W-2 employers.
Mandatory paid sick leave applies to gross wages and accrual rules. Section 125 affects taxable wages, not gross wages or sick-leave accrual. Compliance is unaffected.
No. Section 125 applies only to W-2 employees by IRS rule. NY's recent worker-classification changes (Joint Enforcement Task Force on Worker Misclassification) should be reviewed with your CPA + employment attorney to ensure proper W-2 classification, but Section 125 doesn't change the underlying classification.
No regulatory notification required. Section 125 reduces the payroll base on which your WC carrier rates the premium. Your carrier sees the reduced base at the next audit.

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