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The ESPP $25,000 Limit, Explained (2026)

Updated July 28, 2026. Quick answer: $25,000 per calendar year, measured at the fair market value on the offering date — not by what you contribute and not at the purchase price. With a lookback in a rising stock, that ceiling buys fewer shares than people expect.

Measured at grant, not at purchase

IRC §423(b)(8) caps accrual at $25,000 of stock value per calendar year, valued when the option is granted — the offering date. Because a lookback lets you buy at a discount off the lower price, the number of shares the $25,000 buys is computed off the offering-date price, not the price you actually pay.

Why people are surprised

AssumptionReality
$25,000 of payroll contributions$25,000 of grant-date stock value
Measured at purchase priceMeasured at offering-date FMV
Per offering periodPer calendar year, across all offerings

Overlapping offering periods

Plans with overlapping periods can have two offerings accruing against the same calendar year, which is where the aggregate cap starts binding in ways a single-period calculation misses. Your plan administrator applies this automatically; it is worth understanding why your purchase came back smaller than you budgeted for.

Sources

IRC §423(b)(8); Treas. Reg. §1.423-2(i).

This states what the cited authority says. It is not tax advice.

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