IRS updates DB preapproved plan listing of required modifications
IRS has updated its listing of required modifications (LRMs) for defined benefit (DB) plans, including cash balance plans. LRMs contain sample plan provisions that will satisfy certain applicable requirements of the Internal Revenue Code (IRC) and are intended to help preapproved plan providers prepare their documents for submission to IRS and accelerate the agency’s review of those documents.
The updated LRMs reflect the requirements of the 2026 Cumulative List of Changes for preapproved DB plans published in Notice 2026-34. Plan documents submitted for review for the fourth DB remedial amendment cycle (which began April 1, 2025) must comply with the 2026 cumulative list. Providers have a one-year window starting August 1, 2026, to submit their documents for review.
Although the LRMs are intended to assist providers of preapproved plans, sponsors of individually designed DB plans — who currently cannot request a determination letter for their plan documents except in limited circumstances — may find the IRS-approved sample provisions in the LRMs helpful when drafting required amendments for law changes. Recent major laws that may require plan amendments include 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. (See Retirement plan amendments for recent laws due by December 31.)
Related resources
Non-Mercer resources
- Defined benefit and cash balance listing of required modifications and information package (LRM) (IRS, June 2026)
- Listing of required modifications (LRMs) (IRS)
- Notice 2026-34, 2026 Cumulative list of changes in plan qualification requirements for defined benefit qualified pre-approved plans (IRS, May 14, 2026)
Mercer Law & Policy resources
- Retirement plan amendments for recent laws due by December 31 (July 21, 2026)
- IRS issues 2026 cumulative list of changes for preapproved DB plans (June 2, 2026)