IRS extends IRA amendment deadline for SECURE acts and more
IRS Notice 2026-9 announces a one-year extension — to Dec. 31, 2027 — of the deadline to amend certain individual retirement arrangements (IRAs) for the following laws:
- The SECURE 2.0 Act of 2022
- The Setting Every Community Up for Retirement Enhancement Act of 2019
- The Coronavirus Aid, Relief and Economic Security (CARES) Act
- The Taxpayer Certainty and Disaster Tax Relief Act of 2020
The extended deadline applies to IRAs under Internal Revenue Code (IRC) Section 408(a), (b) and (h) as well as Simplified Employee Pension (SEP) arrangements and Savings Incentive Match Plan for Employees (SIMPLE) IRAs. It covers all amendments — required or discretionary — related to these laws and any associated regulations.
IRS extended the plan amendment deadline in response to feedback from stakeholders that without model language for the required amendments, IRA custodians and providers need additional time. IRS is working on model amendments but hasn’t released them yet.
The extension does not apply to qualified retirement plans, 403(b) plans or eligible 457(b) plans sponsored by governmental employers. The deadline to amend these plans for most provisions in the above laws remains Dec. 31, 2026, except later deadlines apply to amendments for certain changes to the required minimum distribution rules under SECURE 1.0 and 2.0.
Related resources
Non-Mercer resources
- Notice 2026-9 (IRS, Jan. 26, 2026)
- Notice 2024-2 (IRS, Dec. 20, 2023)
Mercer Law & Policy resource
- User's guide to SECURE 2.0 (regularly updated)
- 2025 Required Amendments List includes SECURE acts’ RMD changes (Dec. 8, 2025)
- After empty RA List, IRS delays amendment deadlines for new laws (Dec. 21, 2023)