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FAQs on Form 8905, Certification of Intent to Adopt a Pre-Approved Plan

These FAQs relate to the use of Form 8905, Certification of Intent to Adopt a Pre-Approved Plan.

For more on adopting a pre-approved retirement plan, see


What is the purpose of Form 8905?

Form 8905 is used by an employer who currently has an individually designed retirement plan but plans to adopt a pre-approved retirement plan in the future. It changes the employer’s five-year remedial amendment cycle to the six-year remedial amendment cycle for its pre-approved plan.


When must an employer execute Form 8905?

An employer with an individually designed plan must execute Form 8905 as an “intended adopter” of a pre-approved plan before the end of the employer’s five-year remedial amendment cycle (Revenue Procedure 2007-44, Section 17.04). The Master and Prototype (M&P) sponsor or Volume Submitter (VS) practitioner who maintains the new pre-approved plan must also sign the form.

Exception for Cycle C:


May Form 8905 be signed with an electronic signature?

Only the M&P sponsor or VS practitioner may use an electronic signature. The employer who will adopt the pre-approved plan must manually sign and date the form (stamped or scanned signatures or dates are not valid).


Who is responsible for keeping the signed original of Form 8905?

The employer who will adopt the pre-approved plan is responsible for retaining the Form 8905 signed and dated by the employer and the M&P sponsor or VS practitioner. The original should be filed with the appropriate determination letter application (Form 5300, 5307, or 5310) if such an application is later filed.


When should a plan M&P sponsor, VS practitioner or employer file a Form 8905 with the IRS?

Form 8905 should only be filed as part of an application for a determination letter on Form 5300, 5307 or 5310. Form 8905 should then be attached to the determination letter application. If no Form 5300, 5307, or 5310 is ever filed, the employer should keep the original signed and dated Form 8905 in its records, but should not file it with the IRS.

Page Last Reviewed or Updated: 28-Apr-2014