Are employer retirement plan contributions included in the “retirement plan contributions” when calculating loan amount under Paycheck Protection Program (PPP)?

Yes, they were specifically included in the latest guidance from the Treasury on 4/7/2020.  Q& A # 7.

Question: The CARES Act excludes from the definition of payroll costs any employee
compensation in excess of an annual salary of $100,000. Does that exclusion apply to all
employee benefits of monetary value?

Answer: No. The exclusion of compensation in excess of $100,000 annually applies
only to cash compensation, not to non-cash benefits, including:

- employer contributions to defined-benefit or defined-contribution retirement
- payment for the provision of employee benefits consisting of group health care
coverage, including insurance premiums; and
- payment of state and local taxes assessed on compensation of employees.


NOTE: With respect to eligibility for forgiveness of PPP loan amounts, the following rules apply for contributions made on behalf of owner employees:

  • Retirement plan contributions made for self-employed individuals, sole proprietors, independent contractors, and general partners are not eligible for purposes of loan forgiveness (“Do not add employer retirement contributions made on behalf of a self-employed individual or general partners, because such payments are already included in their compensation, and contributions on behalf of owner employees are capped at 2.5 months’ worth of the 2019 contribution amount.”)
  • Retirement plan contributions paid for owner-employees of an S-corporation and C-corporation are eligible for PPP loan forgiveness. However, based on the guidance in the updated IFR on PPP Loan Forgiveness the total compensation limit still applies.

Compensation limit is the lesser of 2.5 month equivalent of 2019 compensation for a maximum of $20,833 for the 24-week covered period (If electing 8-week covered period: 8/52 of 2019 net profit with a maximum of $15,385 for the covered period) and excluding any qualified sick or family leave equivalent amount for which a credit was claimed under FFCRA or 2020 compensation paid during the covered period

  • Owner-employees of C-corporations: 2019 cash compensation and payment for retirement benefits AND health insurance contributions made on their behalf
  • For owner-employees of S-corporations: 2019 compensation and payment for retirement benefits made on their behalf (health insurance contributions are not included)

Compensation limit is applied in total across all businesses.

Retrieved on April 15, 2020 from

Also, see PPP Loan Forgiveness Application, Instructions p.3 and EZ PPP Loan Forgiveness Application, Instructions p.2.

Cetera Retirement Plan Specialists is a third-party administrator and may not offer tax, legal or investment advice. Plan sponsors should consult their own tax, legal or investment professionals.