Announcement 2023-6

The Internal Revenue Service (IRS) intends to issue opinion letters for pre-approved defined benefit plans that were updated for changes in plan qualification requirements listed in Notice 2020-14, 2020-13 I.R.B. 555 (the 2020 Cumulative List) and that were filed with the IRS during the third six-year remedial amendment cycle under the remedial amendment cycle system for pre-approved plans established under Rev. Proc. 2016-37, 201629 I.R.B. 136 (newly approved plans). The IRS expects to issue the letters on February 28, 2023, or, in some cases, as soon as possible thereafter.

An employer intending to maintain a pre-approved plan for the third six-year remedial amendment cycle for defined benefit plans must adopt a newly approved plan on or before March 31, 2025. During the period beginning April 1, 2023, and ending March 31, 2025, the IRS will accept an application for an individual determination letter from an adopting employer eligible to submit a determination letter request under the third six-year remedial amendment cycle for defined benefit pre-approved plans.

Background