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IRS proposes new forms and procedures to simplify rollovers 

October 15, 2026
IRS Notice 2026-49 provides sample forms and proposed procedures for rollovers to and from employer-sponsored retirement plans. The SECURE 2.0 Act of 2022 directed the IRS to issue sample forms and procedures “to simplify, standardize, facilitate, and expedite” the rollover process. The notice seeks to reduce the burden on participants, including by encouraging direct communication between the plans and electronic fund transfers whenever possible. IRS is accepting comments on the forms and procedures until October 23.

Proposed procedures and sample forms

The notice contemplates a five-step rollover process that includes the use of four separate forms. The participant initiates the process by submitting a request to the plan that will receive the rollover. The receiving plan and the distributing plan then work together to complete the rollover with little to no additional participant involvement. The sample forms can be used in any rollover to or from an employer-sponsored plan but can’t be used in transfers between IRAs. The notice suggests that plans can begin following the proposed process and using the sample forms immediately. The process includes the following steps:

  • Step 1: Participant submits rollover request to receiving plan. A participant requests a rollover by submitting Form 1: Participant’s Rollover Request to the receiving plan. Form 1 includes a “Participant’s Rollover Request Authorization” that authorizes the receiving plan to act on the participant’s behalf to request a rollover and the distributing plan to transfer the funds. 
  • Step 2: Receiving plan submits rollover request to distributing plan. After receiving the Form 1, the receiving plan assigns a “rollover ID number” (or “RIN”) to the rollover, which is added to all communications and forms used in the transaction. The plan then completes and transmits Form 2: Receiving Plan’s Request to Distributing Plan and a copy of the Participant’s Rollover Request Authorization to the distributing plan. Form 2 provides identifying and contact information for the receiving plan, its trustee, and a designated person to resolve issues, as well as acceptable rollover methods and preferred communication methods. The notice encourages receiving plans to identify at least one electronic transfer method.
  • Step 3: Distributing plan verifies accuracy of participant’s request. The distributing plan verifies the information reported on Form 2, which may include confirming the participant is eligible to take a distribution and has actually requested a rollover. Once that information is verified, the distributing plan completes and transmits Form 3: Distributing Plan’s Rollover Certification to the receiving plan to acknowledge the rollover request and to confirm that the distributing plan is tax-qualified and the amount to be transferred is rollover-eligible. The distributing plan also identifies its acceptable rollover methods that match those of the receiving plan. The notice encourages the distributing plan to select at least one electronic transfer method. If the distributing plan’s rollover methods don’t match those of the receiving plan, the plans need to communicate to resolve the difference.
  • Step 4: Receiving plan approves rollover. Upon receiving Form 3, the receiving plan completes and transmits Form 4: Receiving Plan’s Rollover Acceptance to the distributing plan. The receiving plan designates on Form 4 the transfer method that will be used to complete the rollover. Again, the notice encourages the use of an electronic transfer method if possible, but if the only possible transfer method is a paper check, it should be payable to the receiving plan for the benefit of the participant and mailed directly to the receiving plan.
  • Step 5: Distributing plan completes the rollover. After receiving Form 4, the distributing plan transfers the funds to the receiving plan using the selected rollover method.
  • Use of sample forms is optional.

    Plans don’t need to use the sample forms, but IRS encourages plans to use the rollover procedures in the notice, regardless, because other plans may use the sample forms.
  • Forms aren’t safe harbors…yet.

    The notice explains that use of the sample forms does not provide safe harbor relief to either plan in a rollover transaction. However, as noted below, IRS is considering future guidance that would include safe harbors for plans and IRAs that use the sample forms. These safe harbors could allow, for example, a receiving plan to assume that the distributing plan is a qualified plan, and the distributing plan to conclude that withholding is not required on the distribution.
  • Modifications allowed.

    Plans can modify the sample forms as necessary, including to comply with applicable laws (such as federal and state privacy laws). Plans can also provide supplemental or clarifying information, either directly on the forms or in an addendum.
  • Electronic transmission of forms encouraged.

    The notice encourages plans to transmit all four forms electronically. The notice also encourages receiving plans to make Form 1 available to participants electronically, including by use of fillable PDFs or online form fields. Distributing plans are encouraged to make the information participants need for Form 1 available on their websites.
  • Protecting participant data.

    The notice says that if the forms are transmitted electronically, both the receiving and distributing plans should use a secure system that uses data encryption to protect participants’ personally identifiable information. 
  • No effect on other distribution requirements.

    The proposed procedures have no effect on a distributing plan’s other obligations with respect to a rollover distribution, such as providing a Section 402(f) rollover notice or obtaining spousal consent (if applicable).

More guidance in the works

IRS is considering the following additional guidance to further simply and standardize the rollover process:

  • As discussed above, new safe harbors for plans and IRAs that use the sample forms
  • Guidance requiring rollovers to occur via electronic transfer of funds or by paper checks mailed directly to the receiving plan
  • Rescission of existing guidance in Treas. Reg. § 1.401(a)(31)-1, Q&A-4, and Rev. Rul. 2014-9 allowing rollover checks to be sent to participants and forwarded to the receiving plan
  • Guidance prohibiting certain procedures, in addition to those already listed in Treas. Reg. § 1.401(a)(31)-1, Q&A-6(b), such as requiring use of a Medallion Signature Guarantee or distribution letters, and preventing participants from choosing rollover via electronic transfer, assuming both plans have the capacity for it

Request for comments

IRS invites comments on whether and how future guidance could encourage the development of standards and platforms to further simplify the rollover process, and what time frame would be necessary to implement any such guidance. The notice acknowledges, for instance, that plans may need some lead time to build the electronic systems necessary to use electronic transfers for rollovers.

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