On August 5, 2026, the Internal Revenue Service (IRS) issued Announcement 2026-15, stating that it expects to issue opinion letters on August 31, 2026, or as soon as possible thereafter, for defined contribution (DC) qualified pre-approved plans submitted for the fourth remedial amendment cycle, commonly referred to as Cycle 4.
Cycle 4 DC qualified pre-approved plan documents were required to reflect applicable changes in qualification requirements identified in the IRS’s 2023 Cumulative List of Changes in Plan Qualification Requirements for Defined Contribution Qualified Pre-approved Plans (2023 Cumulative List).1 Opinion letters issued by the IRS provide reliance to plan sponsors that the pre-approved plans they adopt meet the updated IRS plan qualification requirements for that restatement cycle.
Providers of DC qualified pre-approved plans submitted applications for Cycle 4 opinion letters during the IRS submission period, which ran from February 1, 2024, through January 31, 2025.
Deadline for employers to adopt a Cycle 4 DC qualified pre-approved plan
Employers that adopt a newly approved Cycle 4 DC qualified pre-approved plan by September 30, 2028, will be considered to have adopted the plan timely within the Cycle 4 remedial amendment period. The September 30, 2028, deadline is expected to be the same for all employers, and the adoption window is designed to give most employers the time needed to complete both the adoption of the plan and the application for an individual IRS determination letter, if applicable.
When applications for an individual determination letter can be made
An employer that adopts a newly approved Cycle 4 DC qualified pre-approved plan that includes limited modifications may apply for an individual determination letter specific to its own plan, if eligible, between October 1, 2026, and September 30, 2028, if the applicable IRS eligibility requirements are satisfied. These requirements generally depend on the type of pre-approved plan adopted and on the type and extent of the modifications made to the specimen IRS-approved document.
Please contact your Milliman consultant to determine how these provisions may impact your plan(s).
1 Our summary of the key changes in the 2023 Cumulative List can be found here.