IRS issues 2026 cumulative list of changes for preapproved DB plans 

Providers can submit their Cycle 4 documents to IRS between August 1, 2026, and July 31, 2027. Once IRS has finished reviewing the submissions, the agency will issue opinion letters to providers whose documents have been approved. Employers may then adopt the plans within a window (usually about two years) announced by IRS. Timely adoption of a newly approved document will allow employers to rely on the provider’s opinion letter retroactively to the beginning of Cycle 4. Rev. Proc. 2023-37 lays out the procedures and timing rules for adopting and amending preapproved plans.

The 2026 Cumulative List covers a host of changes for recently issued regulations and significant pieces of legislation, including the Setting Every Community Up for Retirement Enhancement (SECURE 1.0) Act of 2019, the SECURE 2.0 Act of 2022, the Coronavirus Aid, Relief, and Economic Security Act, the Bipartisan American Miners Act of 2019, and the Taxpayer Certainty and Disaster Tax Relief Act of 2020. Many of the legislation-related changes were explicitly excluded from Cycle 3 review.

When reviewing submissions, IRS won’t consider any guidance issued or statutes enacted after May 14, 2026, the date the list was published. Additionally, IRS will not review Cycle 4 plan documents for SECURE 2.0’s increase in the required minimum distribution triggering age from 73 to 75 because that provision won’t affect the timing of those distributions until after the end of Cycle 4. (The SECURE 1.0 and 2.0 increases from 70 to 72, and then 72 to 73, are included.) IRS also says that, consistent with prior lists, the 2026 Cumulative List doesn’t include routine, ministerial guidance such as annual announcements of inflationary adjustments for retirement plan limits.