Key amendment and restatement deadlines are approaching for many retirement plans. Reviewing your Plan now can help prevent a last-minute rush!
Now is a good time to confirm that your Plan document, Plan operations, and current objectives remain aligned. Your service providers can guide you through the amendment and restatement process, but reviewing these items before the approaching deadlines can reduce last-minute decisions.
All Plans – Required Regulatory Amendments
Retirement plans that are subject to these requirements—including applicable 401(k), 403(b), and 457(b) Plans—must timely adopt amendments related to the CARES Act, the SECURE Act, and SECURE 2.0 no later than December 31, 2026. Compliance providers are working through this complex process; if you have not received an update, contact your compliance provider / TPA to confirm the amendment timeline and the steps required for execution.
Cycle 2 Pre-Approved Documents – 403(b) Plans
403(b) Plans using IRS pre-approved plan documents (which is nearly all 403(b) Plans) generally must be restated on a recurring six-year cycle. The Cycle 2 pre-approved document must be adopted no later than December 31, 2026. If you have not received an update, contact your compliance provider / TPA to confirm the restatement timeline and the steps required for execution.
Cycle 4 Pre-Approved Documents – 401(k) Plans
Similarly, 401(k) Plans are entering their fourth cycle for IRS pre-approved plan document restatements. Cycle 4 documents must be adopted no later than September 30, 2028, and the earliest restatement work is expected to begin in the first quarter of 2027.
A thoughtful review today can help make the upcoming transition more manageable. Reach out to learn more!
About the Author: David Beck
David Beck, CPA, QPA, ERPA, serves as Senior ERISA Consultant for Summit Financial Group, specializing in retirement plans. With over 20 years of experience, he helps organizations navigate plan consulting, design, and administration, including complex corrections under the IRS’s Employee Plans Correction Resolution System (EPCRS). David is an active member of the Connecticut Society of CPA’s Employee Benefits Committee and the American Society of Pension Professionals and Actuaries. Learn more about David by visiting his Summit bio: David Beck.
David Beck is not affiliated or registered with Cetera Wealth Services LLC. Any information provided by David Beck is in no way related to Cetera Wealth Services LLC or its registered representatives.
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