IRS Announces the Resumption of Issuing Opinion Letter for Certain Pre-Approved DC Plans

The Internal Revenue Service (IRS) issued Announcement 2026-15 explaining its intention to release opinion letters for defined contribution qualified pre-approved plans that were updated for changes in the plan qualification requirements listed in the 2023 IRS Cumulative List and filed with the IRS during the fourth remedial amendment cycle (Cycle 4) under the remedial amendment cycle system for pre-approved plans. The IRS plans to issue the opinion 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.

Announcement 2026-15 says that an adopting employer of a newly approved DC qualified pre-approved plan may apply for an individual determination letter during the period that begins October 1, 2026, and ends on September 30, 2028.