Restatement Deadline Extended: 403(b) and Defined Benefit Plans

After the CARES Act was signed into law, the IRS announced that it had extended the remedial amendment periods for 403(b) and defined benefit plans.

403(b) Plans

Prior to this deadline extension, 403(b) plans must have been restated on or prior to March 31, 2020. This extension pushes the deadline to restate out to June 30, 2020. The second cycle for 403(b) pre‑approved plans will begin July 1, 2020.

Pre-Approved Defined Benefit Plans

The April 30, 2020 deadline for employers to adopt a pre-approved defined benefit plan and to submit a determination letter application (if eligible) under the second six-year remedial amendment cycle is extended to July 31, 2020.

The April 30, 2020 end date of the second six-year remedial amendment cycle for pre-approved defined benefit plans is extended to July 31, 2020.

The third six-year remedial amendment cycle for pre-approved defined benefit plans will now begin on August 1, 2020. The end date has not been extended, it will still end on January 31, 2025.