Required Amendments List

The Required Amendments List is an annual list of changes in retirement plan qualification requirements (see Revenue Procedure 2016-37). It also establishes amendment deadlines for individually designed plans.

Generally, the Required Amendments List will include an item after guidance for the item (including any model amendment) is issued. At the IRS’s discretion, however, the List may also include an item in other circumstances, such as when a statutory change is enacted and no additional guidance is anticipated.

Plan amendment deadline

The plan amendment deadline for most items on each list will be the end of the second calendar year following the year in which the list is issued unless noted otherwise.

Required Amendments Lists

Year Required Amendments List General Plan Amendment Deadline
2016 Notice 2016-80 December 31, 2018
2017 Notice 2017-72 December 31, 2019
2018 Notice 2018-91 December 31, 2020

Cumulative List

Following the elimination of the five-year staggered remedial amendment cycle for individually-designed plans, the IRS will no longer publish the Cumulative List of Changes in Qualification Requirements - an annual 5-year compilation of qualification changes for individually designed plans. See New Determination Program Rev. Proc. 2016-37 for a summary of this change. However, the IRS intends to publish cumulative lists for pre-approved plans submitted for an opinion or advisory letter.

Additional resources