For retirement plan sponsors, the next few years will bring important updates to plan documents. Several IRS-required restatement cycles are underway or have recently been completed, and key legislation (including the SECURE Act, CARES Act, and SECURE 2.0) requires formal amendments. While it may seem like a lot to manage, Blue Ridge Associates is here to guide you through each step and help ensure your plan remains compliant.
What Is a Restatement?
Every six years, the IRS requires preapproved retirement plans to undergo a restatement—a complete rewrite of the plan document to include recent legislative and regulatory changes. This process ensures your plan stays up to date and provides a great opportunity to review and improve your plan design. There are separate cycles for different types of plans: defined contribution (like 401(k) plans), 403(b) plans, and defined benefit/cash balance plans.
Defined Benefit and Cash Balance Plans: Cycle 3 Just Ended
The latest restatement cycle for defined benefit and cash balance plans, known as Cycle 3, ended on March 31, 2025. If you sponsor one of these plans, your updated document should have been adopted by that date.
403(b) Plans: Cycle 2 Restatement Is Now Open
If you sponsor a 403(b) plan, the new restatement period began on January 1, 2025, and runs through December 31, 2026. This is the second official restatement cycle for 403(b) plans, so it is known as the “Cycle 2” restatement.
Blue Ridge Associates is currently finalizing its review of the Cycle 2 document and will contact plan sponsors when we’re ready to begin drafting restated plan documents. In the meantime, employers should start thinking about any plan changes that they may want to make with the restatement.
401(k) Plans: Cycle 4 Coming Soon
The last 401(k) plan restatement cycle (Cycle 3) ended on July 31, 2022. The next cycle, “Cycle 4,” is expected to begin in late 2026. No immediate action is needed now, but if you’re considering changes to your plan design, it’s a good idea to keep those ideas in mind for when the new cycle begins.
SECURE, CARES, and SECURE 2.0 Amendments: Due December 31, 2026
In addition to the restatement process, nearly all retirement plans must be formally amended to reflect the SECURE Act (2019), CARES Act (2020), and SECURE 2.0 Act (2022) by December 31, 2026. While the IRS has given extra time to adopt the amendment, many of the rules are already in effect, so it’s important that plans begin operating in accordance with the new rules.
Some of the key changes include:
- Expanded eligibility for long-term, part-time employees
- Required Roth catch-up contributions for high earners
- Increased automatic rollover threshold
- Optional provisions such as emergency expense distributions, distributions for victims of domestic abuse, and increased catch-up limits for those ages 60-63.
Blue Ridge Associates is actively preparing for the required amendments and will keep you informed as we move forward.
Keeping your retirement plan document up to date isn’t just about meeting IRS deadlines, it’s about ensuring your plan operates as intended. If you have questions or want to discuss possible updates, reach out to your Blue Ridge Associates administration consultant.
