IRS Clarifies When Retirement Plans Must Be Updated for SECURE and SECURE 2.0

Most plan sponsors have treated December 31, 2026, as the deadline for adopting plan amendments under the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act) and the SECURE 2.0 Act of 2022 (SECURE 2.0). On September 18, 2026, the Internal Revenue Service (IRS) clarified in its Employee Plans newsletter that the deadline depends on whether an amendment is required or discretionary.

Certain required amendments follow the IRS Required Amendments List (RA List) process and will have deadlines after 2026. Discretionary amendments generally remain subject to the December 31, 2026, deadline.

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Treasury and IRS Issue Sample Rollover Forms under SECURE 2.0

On August 12, 2026, the Treasury Department and the Internal Revenue Service (IRS) released Notice 2026-49, providing the first formal guidance under the SECURE 2.0 Act on simplifying and standardizing the rollover process for qualified retirement plans. Below are key takeaways for retirement plan sponsors.

Background

Section 324 of the SECURE 2.0 Act directed the Treasury Department to develop sample forms and procedures designed to simplify and standardize rollovers to eligible retirement plans and trustee-to-trustee transfers from individual retirement plans. The guidance responds to longstanding concerns that the rollover process has been inefficient, inconsistent, and overly burdensome for participants. Please note that the sample forms are not intended to be used for IRA-to-IRA rollovers or transfers but may be used for rollovers to or from an IRA.

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