Important Deadlines and Submission Periods for Retirement Plans

At RPAG, we are committed to providing our members with the necessary resources and support to ensure their retirement plans remain compliant with current regulations. It's crucial for plan sponsors and providers to stay informed of important deadlines and submission periods to avoid any potential compliance issues or penalties. Our dedicated team is here to guide you through these updates and provide any assistance you may need. Please see below for detailed information on upcoming deadlines and submission periods.

Defined Benefit Plan Sponsors: Plan Restatement Period

For plan sponsors of defined benefit plans that use an IRS pre-approved document, the restatement period with a 3rd cycle document must be completed by March 31, 2025. This deadline provides sufficient time for plan sponsors to review and amend their plan documents to comply with any changes in regulatory requirements. Failure to restate your plan by this date may result in compliance issues and potential penalties.

It's important to note that during the period of April 1, 2023, through March 31, 2025, the IRS will accept applications for an individual determination letter from eligible employers that adopted a 3rd cycle pre-approved defined benefit plan. Eligible employers should take advantage of this opportunity to ensure their plan document is compliant with current regulations. 

Pre-Approved Plan Providers: Submission Period for 4th Cycle Defined Contribution (DC) Opinion Letters

Pre-approved plan providers and mass submitters should wait to apply for a 4th remedial amendment cycle (RAC) DC Opinion Letter until the IRS announces the opening of the one-year on-cycle submission window. The 3rd pre-approved DC RAC ended on January 31, 2023, which means that the 4th RAC began on February 1, 2023; however, the submission window has not yet opened.

The IRS is expected to issue an announcement later this year that opens the on-cycle submission window from February 1, 2024, through January 31, 2025. Revenue Procedure 2016-37, section 16.03 provides the IRS with flexibility to revise a particular RAC by announcing the revision in future guidance. This flexibility ensures that the proper time and resources are available during each RAC, which is beneficial to both the IRS and plan providers.

Pre-Approved Plan Providers: Submission Period for Cycle 2 403(b) Plan Opinion Letters

The submission period for 403(b) pre-approved plan providers to submit applications for a Cycle 2 Opinion Letter ends on May 1, 2023. Plan providers should review the required items and application steps for submission on the IRS website to ensure compliance with current regulations.


It's important for retirement plan sponsors and providers to stay informed about upcoming deadlines and submission periods to ensure compliance with current regulations. Failure to comply may result in penalties, fines, and potential legal issues. RPAG is here to help guide you through these important updates and ensure your retirement plan remains compliant. Please reach out to us if you have any questions or concerns.


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