Cycle II 403(b) Plan Restatement

To maintain compliance with Internal Revenue Service (IRS) requirements, all 403(b) retirement plans must be periodically updated to reflect current laws and regulations. This process, known as a plan restatement, ensures that your 403(b) plan remains a tax-qualified retirement plan under federal law.

The IRS reviews and approves plan provisions on a six-year cycle. The current cycle, referred to as Cycle II, is now underway. As a 403(b)(9) plan provider, we will guide you through this important compliance milestone. Throughout 2026, you will receive communications from us outlining your next steps and providing the necessary documents and instructions to complete your plan restatement.

What Is a Plan Restatement?

A plan restatement means adopting a new version of your 403(b) plan document that incorporates all IRS-required updates since the last restatement cycle. These changes capture recent tax laws, Treasury regulations, and IRS guidance that affect how 403(b) plans operate.

While some updates may seem technical, they are essential to maintain the plan’s qualified status and protect both the employer and participants from potential tax issues.

In simple terms, restatement ensures your plan’s written document matches how it is actually operated and aligns with the latest legal standards.

Restatement Timeline and Deadline

The IRS has established December 31, 2026, as the final deadline to adopt the Cycle II restated 403(b) plan documents.

Even if you recently adopted or amended your plan, a restatement may still be required if your current plan document predates the latest IRS-approved version. Failing to restate the plan by the deadline could result in loss of qualified plan status, leading to significant tax consequences for both your organization and participants.

To help you stay on track, our team will provide detailed instructions and supporting materials well before the deadline.