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The IRS recently released Notice 2026-34 (PDF - 144.87KB), which provides the 2026 Cumulative List of Changes in Plan Qualification Requirements for Pre-Approved Defined Benefit Plans.
In section IV of the notice, the 2026 Cumulative List sets forth specific items the IRS has identified for review in determining whether the form of a defined benefit qualified pre-approved plan submitted to the IRS for an opinion letter for the fourth remedial amendment cycle (Cycle 4) has been properly updated since the plan was submitted for a Cycle 3 opinion letter.
The 2026 Cumulative List identifies recent changes in the qualification requirements of the Internal Revenue Code that were not taken into account during the first three remedial amendment cycles for defined benefit qualified pre-approved plans and that will be taken into account by the IRS with respect to the form of a plan submitted to the IRS for Cycle 4.
Applicable changes include, but are not limited to, the following topics:
- The required beginning date and other changes to required minimum distribution (RMDs);
- Certain involuntary distributions and cash-outs;
- Distributions during working retirement;
- Use of forfeitures within the plan; and
- Disaster-related rules.
Pre-approved plan providers can use the cumulative list to update their pre-approved defined benefit plans for the Cycle 4 amendment cycle and submit their updated plans to the IRS during the on-cycle submission period, which begins on Aug. 1, 2026, and ends on July 31, 2027.
The list of changes in section IV of the notice does not extend the deadline by which a plan must be amended to comply with any change in the qualification requirements applicable to the plan. Consistent with previous Cumulative Lists, the 2026 Cumulative List does not include routine, ministerial guidance (such as guidance that is typically issued annually to announce a cost-of-living adjustment to a qualified plan contribution limit).
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