IRS Releases 2026 Cumulative List of Changes in Plan Qualification Requirements for DB Pre-approved Plans

Published May 15, 2026

The Internal Revenue Service (IRS) issued Notice 2026-34 to be used by pre-approved plan providers to submit opinion letter applications for pre-approved defined benefit plans during the fourth remedial amendment cycle, which begins August 1, 2026, and ends July 31, 2027.

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 IRS with respect to the form of a plan submitted to IRS for Cycle 4.

Changes included in the cumulative list relate to:

Required minimum distributions
Designated beneficiaries
Distributions
Forfeitures
Nondiscrimination relief
Accrued benefits
Rollover distributions
Partial terminations
Cash balance plans
Minimum value requirements
Domestic relations orders
Transfer of excess pension assets