IRS Offers Reference Lists for Plan Qualification Requirements

The Internal Revenue Service (IRS) offers fillable reference lists of changes in qualification requirements for retirement plans.

Reference lists are tools to help plan sponsors ensure that their plan document incorporates all relevant mandatory and optional changes in plan qualification requirements. Each reference list contains items that are new to the cumulative list for a given year.

For determination letter applications, a plan sponsor with an individually designed plan submitted on Form 5300 would complete the five reference lists for the five years of its remedial amendment cycle (RAC). These are the years covered by the cumulative list applicable to the submission. An employer adopting a volume submitter plan and submitting on Form 5307 would complete the six reference lists for the six years in its RAC.

For interim amendments, the IRS recommends completing each year’s reference list to check whether the plan document is up-to-date. If a plan sponsor missed any relevant amendments, its plan may have a qualification failure and it must correct this error.

Although not mandatory, the IRS encourages plan sponsors to include completed reference lists with determination letter applications. This will facilitate IRS review of the plan document.

The reference lists and instructions for how to complete them can be found here.