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.
What the Notice Provides
Notice 2026-49 proposes four sample forms to guide distributing plans and receiving plans through the rollover procedure:
- Form 1 — Participant’s Rollover Request: The participant submits a rollover request and authorization to the receiving plan.
- Form 2 — Receiving Plan’s Request to Distributing Plan: The receiving plan submits the rollover request and authorization to the distributing plan and assigns a unique rollover identification number (RIN) to track the transaction and protect personal identifying information (PII).
- Form 3 — Distributing Plan’s Rollover Certification: The distributing plan verifies the accuracy of the information on Form 1.
- Form 4 — Receiving Plan’s Rollover Acceptance: The receiving plan verifies that it can receive the rollover and selects the transfer method, after which the rollover would be completed using the selected transfer method.
Use of the sample forms is optional, and use of the forms does not currently provide a safe harbor for plans. However, the IRS is actively considering future safe harbor guidance and has invited public comment on the forms and related issues by October 23, 2026.
Key Features and Themes
The sample forms and proposed rollover procedures are designed around several core protocols:
- PII protection through a Rollover Identification Number (RIN): Each rollover is assigned a unique RIN by the receiving plan, which is used in all communications between plans in lieu of transmitting the participant’s full Social Security number.
- Plan-to-plan coordination: The forms require the distributing and receiving plans to communicate directly and verify information, reducing the participant’s role as intermediary.
- Standardized data fields: The forms use a common set of data elements and terminology throughout the rollover process to promote uniformity across plans.
- Electronic transfers encouraged: Consistent with federal policy favoring electronic payments, the forms are designed to encourage plans to complete rollovers electronically to the maximum extent possible.
Separately, the notice describes several areas where the Treasury Department and IRS are considering future rulemaking that could go beyond the voluntary sample forms, including eliminating rollover checks to participants, mandatory electronic or direct-to-plan transfers, safe harbors tied to use of sample forms, and designating certain common practices (such as medallion signature guarantees) as impermissible procedures.
Practical Considerations for Plan Sponsors
Although use of the sample forms is optional, plan sponsors may consider evaluating their current rollover procedures with the plan’s third-party administrators in light of this guidance, including how PII is currently handled and the feasibility of adopting electronic transfer methods for rollovers.
The material contained in this communication is informational, general in nature and does not constitute legal advice. The material contained in this communication should not be relied upon or used without consulting a lawyer to consider your specific circumstances. This communication was published on the date specified and may not include any changes in the topics, laws, rules or regulations covered. Receipt of this communication does not establish an attorney-client relationship. In some jurisdictions, this communication may be considered attorney advertising.
