A new chapter begins
IRS offers new tool for tracking preapproved plan cycles
A new web page from the IRS summarizes the remedial amendment cycles for preapproved defined contribution (DC), defined benefit (DB) and 403(b) plans. The table contains the full history of the applicable starting and ending dates for each plan type, for every cycle, from the first to the most recent.
All preapproved plans are subject to six-year remedial amendment cycles. Early in each cycle, preapproved plan providers can apply for opinion letters confirming that their updated documents satisfy recent changes in the qualification or 403(b) requirements. Once IRS issues opinion letters, providers make their documents available for employers to adopt during the window announced by the IRS. The window is usually about two years and ends of the last day of the cycle. Timely adoption allows an employer to rely on the provider’s opinion letter for that cycle as if the opinion letter were the sponsor’s own.
The most recent remedial amendment cycle for each type of preapproved plan is shown below. IRS hasn’t yet issued opinion letters for the fourth cycle for DC plans, so that cycle’s end date hasn’t been determined.
| DC | DB | 403(b) | |
|---|---|---|---|
| Current cycle number | 4 | 3 | 2 |
| Timely submission period | Feb. 1, 2024 – Jan. 31, 2025 |
Aug. 1, 2020 – July 31, 2021 |
May 2, 2022 – May 1, 2023 |
| Cycle end (and employer adoption deadline) | Not yet announced | March 31, 2025 | Dec. 31, 2026 |
Related resources
Non-Mercer resources
- Remedial amendment cycle for preapproved plans (IRS, April 3, 2025)
- Preapproved plans — Adopting employer (IRS, periodically updated)
- List of preapproved plans (IRS, periodically updated)
Mercer Law & Policy resources
- Deadline nears to adopt preapproved DB plans for third cycle (March 10, 2025)
- IRS announces Cycle 2 preapproved 403(b) plans and other guidance (Dec. 19, 2024)
- Cycle 4 submissions open for preapproved qualified DC plans (June 5, 2024)