a-26-15.pdf

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Fourth Remedial Amendment Cycle for Defined Contribution Qualified
Pre-approved Plans: Issuance of Opinion Letters, Plan Adoption Deadline, and
Opening of Determination Letter Program

Announcement 2026-15
Section 1. Purpose
The Internal Revenue Service (IRS) intends to issue opinion letters for defined
contribution qualified pre-approved plans that were updated for changes in plan
qualification requirements listed in the 2023 Cumulative List in Notice 2024-3, 2024-2
IRB 338 and that were filed with the IRS during the fourth remedial amendment cycle
(Cycle 4) under the remedial amendment cycle system for pre-approved plans
established under Rev. Proc. 2023-37, 2023-51 IRB 1491. The IRS expects to issue the
letters on August 31, 2026, or as soon as possible thereafter.
This announcement provides a deadline for when an employer intending to maintain a
Cycle 4 defined contribution qualified pre-approved plan must adopt that plan. In
addition, the announcement sets forth the period during which the IRS will accept an
application for an individual determination letter from an adopting employer of a Cycle 4
defined contribution qualified pre-approved plan that is eligible to submit a determination
letter request.
Section 2. Background
Rev. Proc. 2023-37 describes a recurring remedial amendment cycle system for
pre-approved plans. The revenue procedure provides separate remedial amendment
cycles for defined contribution qualified pre-approved plans, defined benefit qualified
pre-approved plans, and section 403(b) pre-approved plans.
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Section 8 of Rev. Proc. 2023-37 provides that the schedules for pre-approved plan
cycles are available at https://www.irs.gov/retirement-plans/determination-opinion-and-
advisory-letters-6-year-cycle-for-pre-approved-plans-plans. Section 8 further provides
that the IRS may revise the schedules to respond to changing circumstances and the
needs of adopting employers, and that any such revision will be reflected in guidance
published in the IRB (either in a revenue procedure, an announcement, or in the
applicable cumulative list).

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The terms “remedial amendment cycle,” “qualified pre-approved plan,” “section 403(b) pre-approved
plan,” “adopting employer,” and “employer adoption window” have the same meaning as “Remedial
Amendment Cycle,” “Qualified Pre-approved Plan,” “Section 403(b) Pre-approved Plan, “Adopting
Employer,” and “Employer Adoption Window” as used in sections 4.01(17), 4.02(2), 4.03(7), 4.01(1), and
4.01(6) of Rev. Proc. 2023-37, respectively.

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In order to receive opinion letters with respect to Cycle 4, Rev. Proc. 2023-37 and the
2023 Cumulative List require that providers update their defined contribution qualified
pre-approved plans for changes in plan qualification requirements set forth in the 2023
Cumulative List.
Section 5.02 of Rev. Proc. 2023-37 provides that when the review process for a cycle of
pre-approved plans is near completion, the IRS will announce the employer adoption
window for that cycle and the adopting employer must adopt a newly approved pre-
approved plan during that window. The employer adoption window is also generally the
period during which an adopting employer of a newly approved pre-approved plan may
file for a determination letter, if applicable, pursuant to section 25 of Rev. Proc. 2023-37.
As described in section 5.02 of Rev. Proc. 2023-37, the deadline to adopt a newly
approved pre-approved plan is expected to be a uniform date that will apply to all
adopting employers, and it is expected that the employer adoption window will provide
virtually all employers approximately two years to adopt a newly approved pre-approved
plan and file for a determination letter, if applicable.
Section 3. Deadline for Employer Adoption of Cycle 4 Defined Contribution
Qualified Pre-approved Plans
The end of Cycle 4 for defined contribution qualified pre-approved plans is September
30, 2028. An adopting employer that has a defined contribution qualified pre-approved
plan that is eligible for the remedial amendment cycle system under section 5 of Rev.
Proc. 2023-37, and that adopts a newly approved pre-approved plan on or before
September 30, 2028, will be considered to have adopted the plan within Cycle 4.
Section 4. Determination Letter Program for an Adopter of a Cycle 4 Defined
Contribution Qualified Pre-approved Plan
An adopting employer of a newly approved defined contribution qualified pre-approved
plan may apply for an individual determination letter (if otherwise eligible) during the
period beginning October 1, 2026, and ending September 30, 2028. Additional
information regarding individual determination letter applications for pre-approved plans,
including guidance on employer eligibility to apply for a determination letter for a pre-
approved plan and the requirements for applications filed on Form 5307, Application for
Determination for Adopters of Modified Nonstandardized Pre-Approved Plans (or Form
5300, Application for Determination for Employee Benefit Plan, if applicable), may be
found in Rev. Proc. 2026-4, 2026-1 IRB 160, including sections 8, 12, and 13.
Section 5. Paperwork Reduction Act
The collection of information contained in Rev. Proc. 2023-37 relating to the
pre-approved plan program has been reviewed and approved by the Office of
Management and Budget (OMB) under OMB Control Number 1545-1674 in accordance

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with the Paperwork Reduction Act (44 U.S.C. 3507). This announcement does not
create any new or additional information collection requirements.
Section 6. Drafting Information
The principal author of this announcement is Isaac Stein of the Office of Associate Chief
Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes). For
further information regarding this announcement, contact Employee Plans at (513) 975-
6319 (not a toll-free number).