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 was used by an employer who had an individually designed retirement plan but planned to adopt a pre-approved retirement plan in the future. It changed the employer’s five-year remedial amendment cycle to the six-year remedial amendment cycle for its pre-approved plan. Please note that this form became obsolete after 1-31-17 due to the discontinuance of the five-year remedial amendment cycles for individually designed plans.

When did an employer execute Form 8905?

An employer with an individually designed plan had to 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 maintained the new pre-approved plan also had to sign the form.

Exception for Cycle C:

Could Form 8905 be signed with an electronic signature?

Only the M&P sponsor or VS practitioner could use an electronic signature. The employer had to 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 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.