IRS Issues Extension for Required Plan Amendments

The IRS recently announced an extension to the deadline for plan document amendments related to 2019’s SECURE Act and 2020’s CARES Act. The initial deadline was Dec. 31, 2022. The new deadline for non-governmental plans is Dec. 31, 2025.

This extension includes the provisions in the SECURE Act, the Miners Act, and the waiver of required minimum distributions (RMDs) as part of the CARES Act.

It is important to note that CARES Act provisions other than the waiver of RMDs are not included in the extension. Pending further guidance, the deadline to amend for coronavirus-related distributions and loans has not changed and is still Dec. 31, 2022.

This extension applies to non-governmental qualified plans and IRAs. For qualified governmental plans, the deadline is 90 days after the close of the third regular legislative session of the body with the authority to amend the plan that begins after Dec. 31, 2023. There are further special rules for governmental 457(b) plans.

Plan sponsors should work with their document provider to ensure that all required plan amendments are made on time and in line with IRS guidance. Review the IRS’s notice here. For questions, contact your Multnomah Group consultant.


Multnomah Group is a registered investment adviser, registered with the Securities and Exchange Commission. Any information contained herein or on Multnomah Group’s website is provided for educational purposes only and does not intend to make an offer or solicitation for the sale or purchase of any specific securities, investments, or investment strategies. Investments involve risk and, unless otherwise stated, are not guaranteed. Multnomah Group does not provide legal or tax advice.

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