Five things to know about the IRS’s latest DC plan restatement cycle

1 IRS Announcement 2026-15

On August 5, 2026, the IRS issued Announcement 2026-15, notifying the retirement industry that opinion letters would be issued on August 31, 2026, or as soon as possible thereafter, for DC pre-approved plans that were updated for the plan qualification requirements listed in IRS Notice 2024-3. Plan sponsors can rely on these opinion letters to show their pre-approved plan document meets the updated qualification requirements for Cycle 4. 

Alternatively, if a sponsor adopts a newly approved Cycle 4 plan document with limited modifications, they may apply for an individual determination letter specific to their own plan between October 1, 2026, and September 30, 2028, if eligible.

2 Recent regulatory changes

Cycle 4 incorporates all the changes made by the CARES Act and SECURE Act. It doesn’t, however, include all the changes made by SECURE 2.0. That’s because the IRS hasn’t had time to issue guidance on all the SECURE 2.0 provisions. Sponsors may need to amend their Cycle 4 plan document when future IRS SECURE 2.0 guidance is issued.

3 Deadline overlap

The Cycle 4 restatement deadline overlaps with the December 31, 2026, deadline to amend most plans for the CARES, SECURE, and SECURE 2.0 Acts. Plan sponsors must comply with both deadlines. 

4 No more flexible discretionary matches

For Cycle 3 restatements, the IRS permitted plans to adopt flexible discretionary matching formulas. If they did, their plan documents had to incorporate notice requirements to comply with the regulations’ “definitely determinable” benefit provisions. Starting with Cycle 4, the IRS will no longer permit matching formulas that it considers undeterminable. In other words, plans must now include a clear, predetermined formula for allocating contributions.

5 Plan terminations

If you’re terminating your plan, you must update your plan document for all required legislative changes before the plan’s termination date.

Final thoughts on Cycle 4

Keeping your plan document up to date for legislative and discretionary plan changes is one of your core responsibilities as a plan sponsor. So, it’s important to understand the Cycle 4 restatement process and applicable deadlines. You’ll also need to update your Summary Plan Description (SPD) and distribute any required Summary of Material Modifications (SMM) to your plan participants and beneficiaries. The good news is that you don’t have to do this alone. Your document provider plays a vital role in the process, helping you amend and restate your DC plan in a timely manner.   

FAQs

What’s the difference between a plan restatement and a plan amendment?

A plan restatement is a full rewrite of the plan document that incorporates all required legal updates and prior amendments into one document. A plan amendment, on the other hand, is a targeted change that updates specific plan provisions. Restatements happen on a set cycle, while amendments are made as laws change or plan features are added, removed, or modified.

Which retirement plans are subject to the IRS six-year restatement cycle?

Cycle 4 applies to plan sponsors who use a pre-approved plan document. Sponsors who use individually designed plan documents have different timelines and requirements for updating their plans in response to legislative changes.

What happens if a plan sponsor misses the Cycle 4 restatement deadline?

If a plan sponsor doesn't adopt a restated plan document by the prescribed deadline, the plan will lose reliance on the opinion letter and will be treated as an individually designed plan. In addition, any language defects in the current document can lead to plan disqualification by the IRS. However, the failure may be corrected under the IRS Employee Plans Compliance Resolution System (EPCRS).