Key Takeaway
Revenue Procedure 2026-34 expands and formalizes opportunities for retirement plan sponsors to correct certain plan errors through EPCRS, including failures involving plan loans, automatic enrollment and overpayments. The changes may allow more eligible errors to be addressed through self-correction rather than the Voluntary Correction Program. Separately, Revenue Procedure 2026-33 establishes a new IRA Compliance Resolution System (ICRS), effective May 1, 2027.
Full Article
The IRS recently issued Revenue Procedure 2026-34, which expands the Employee Plans Compliance Resolution System (EPCRS) and the opportunities available to retirement plan sponsors to self-correct certain plan errors. This will expand the types of inadvertent plan failures that can be corrected without prior IRS approval and potentially avoid Voluntary Correction Program (VCP) fees.
What retirement plan errors can be self-corrected under the updated EPCRS?
The primary areas of expansion include:
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Loans – Expands the types of plan loan failures that can be self-corrected.
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Automatic Enrollment – Makes permanent safe harbor rules related to administrative errors related to certain auto-enroll programs.
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Overpayments – Eases the corrective payment requirements for overpayments made from the plan.
Many of these rules were already in place, but the revenue procedure makes them part of the formal EPCRS structure.
Separately, Revenue Procedure 2026-33 establishes the IRA Compliance Resolution System (ICRS), effective May 1, 2027. At launch, ICRS will provide a voluntary correction process for certain eligible inadvertent IRA failures caused by service provider errors and a formal process for requesting waivers of the 60-day rollover requirement.
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