IRS releases 2026 mortality tables for defined benefit plans 

Generally, mortality tables under IRC section 430 are used to determine DB plans’ minimum funding requirements and for other funding-related purposes, such as calculating variable-rate premiums payable to the Pension Benefit Guaranty Corp. (PBGC). The static tables in Notice 2025-40 may be used for these purposes only by small plans (with no more than 500 participants), multiemployer plans, and cooperative and small-employer charity (CSEC) plans. All other DB plans must use “generational” mortality tables. Generational tables are based on the same underlying mortality rates and projection scale but are more computationally complex. Funding mortality is unchanged for plans using the generational tables.

Modified versions of the 2026 funding mortality tables are the basis of the unisex mortality rates for determining present values for minimum lump sums and other accelerated forms of payment under IRC section 417(e). These tables are used for all DB plans, regardless of whether they use static or generational mortality for funding and related purposes.

The 2026 mortality tables use base mortality rates from Pri-2012, the latest table for US private-employer DB plans from the Society of Actuaries Retirement Plans Experience Committee (RPEC), along with a modified version of RPEC’s latest published mortality improvement scale, MP-2021. The modified projection scale reflects the 0.78% cap on the annual mortality improvement factors, as required by the SECURE 2.0 Act of 2022. The adjusted scale also reflects no mortality improvement for 2020 to 2023 to approximate the impact of the COVID-19 pandemic. IRS hasn’t adjusted the MP-2021 rates after 2023 but has said it intends to consider new data on mortality trends as it becomes available.

In isolation, the changes to the mortality table will increase minimum lump sums by a minimal amount ­­— 0.15%-0.20%. Sponsors using the static tables for funding can expect to see a similar increase in liabilities. However, changes in interest rates will generally dwarf the effect of the change in mortality.