Is Your Retirement Plan Compliant? RMDs, Attribution Rules, and Plan Amendments
Have you ever sat down with a cup of coffee, ready to tackle your “to-do” list, only to be met with a new IRS notice that looks like it’s written in a secret code? Trust me, I’ve been there! Staying on top of retirement plan compliance often feels like trying to hit a moving target while wearing a blindfold. But don’t worry—I’ve spent some quality time with the recently released Notice 2025-60, and I’m here to translate all that “legalese” into plain English for you. Whether you’re an HR professional, a small business owner, or a plan administrator, we’re going to get through this together and make sure your plan stays in the clear. Let’s dive in! 😊
What is the 2025 Required Amendments List? 🤔
Every year, the IRS releases what they call the “Required Amendments List,” or the RA List for short. Think of it as a mandatory “update notification” for your retirement plan’s legal documents. If you manage an individually designed qualified plan (like a 401(k) or a profit-sharing plan) or a 403(b) plan, this list tells you exactly which changes in the law must be written into your plan document to keep its tax-favored status.
The 2025 RA List, established by Notice 2025-60, is particularly important because it marks a transition point for several major pieces of legislation we’ve been tracking for years, including the SECURE Act and the SECURE 2.0 Act. To be honest, it’s not just about adding a few sentences here and there; it’s about ensuring that the way you operate your plan matches what’s written in your plan document.
The RA List generally only includes changes where the IRS has already provided guidance. If a law changed but the IRS hasn’t told us exactly how to implement it yet, it usually won’t show up on the list until a future year.
Mark Your Calendars: Deadlines for 2027 and Beyond 📊
One of the most common questions I get is, “When do I actually have to have these papers signed?” For the items specifically listed on the 2025 RA List, the general deadline for individually designed plans is December 31, 2027. This gives you a bit of a “remedial amendment period” to get your house in order.
However, it’s not a one-size-fits-all situation. Depending on whether your plan is a standard corporate plan, a governmental plan, or a collectively bargained plan, your specific “drop-dead” date might be different. It’s always better to be early than to be scrambling during the holidays in 2027!
Amendment Deadlines by Plan Type
| Plan Type | General Deadline | Applies To |
|---|---|---|
| Individually Designed (Private) | Dec 31, 2027 | Notice 2025-60 Items |
| Governmental Plans | Dec 31, 2029 | Extended per SECURE 2.0 |
| Pre-Approved Plans (Interim) | Dec 31, 2027 | Interim updates |
Even if the formal amendment deadline is years away, you must operate the plan in accordance with the new laws as of their effective dates. Failing to do so can lead to costly corrections later.
Deep Dive: The 2025 Required Amendments 🧮
The 2025 RA List is divided into parts. “Part A” contains the big hitters—the ones that almost every plan will need to address. This year, the spotlight is firmly on Required Minimum Distributions (RMDs).
📝 Major Changes: RMD Final Regulations
The IRS recently finalized regulations (89 Fed. Reg. 58886) that incorporate changes from both the original SECURE Act and SECURE 2.0. This includes:
- Updated “Required Beginning Dates” for participants (shifting from age 72 to 73, and eventually 75).
- The “10-Year Rule” for beneficiaries who are not “Eligible Designated Beneficiaries.”
- Specific rules for “Stretch” RMDs that were restricted by the SECURE Act.
Another technical but important update in “Part B” involves the Partnership and Trust Attribution Rules. This specifically affects how “controlled groups” are determined. If you have a complex business structure with multiple partnerships or trusts, this could change whether certain companies are considered “one employer” for benefits purposes.
🔢 RMD Age Checker 🔢
Not sure when your participants need to start taking money out? Select their birth year below to see their Required Beginning Date age.
The Missing Link: Where is the Roth Catch-Up? 🕵️♀️
You might be looking through the list and wondering, “Wait, where is the Roth Catch-Up requirement (Section 603)?” If you’ve been following the SECURE 2.0 news, you know this has been a major headache for payroll providers.
Here’s the deal: The IRS explicitly stated in Notice 2025-60 that Section 603 (which requires catch-up contributions for high-earners to be Roth) does not appear on the 2025 RA List. Why? Because the IRS provided a transition period until 2026, and they expect to include it on the 2027 RA List instead. So, while you still need to prepare for it operationally, you don’t need to rush the formal amendment for it right now under this specific notice.
Even though it’s not on the 2025 list, keep an eye on your payroll system’s ability to track “catch-up” contributions for employees earning over $145,000 (indexed). That’s the part that catches people off guard!
A Real-World Example: The “Small Business Blues” 📚
Let’s look at how this impacts a typical small business. Imagine “Green Garden Supply,” a company with an individually designed 401(k) plan. They haven’t updated their plan document since 2022.
Case Study: Green Garden Supply
- Status: Plan document lists RMD age as 72.
- Problem: Several long-term employees turned 73 in 2024 and didn’t take distributions because the new law allows them to wait.
The Solution Process
1) The plan administrator confirms that Notice 2025-60 requires the document to reflect the 89 Fed. Reg. 58886 regulations.
2) They have until December 31, 2027, to formally amend the document, but they must make sure their recordkeeper is already using the age 73/75 rules today.
Final Result
– Compliance: By adopting the amendment by late 2027, they avoid plan disqualification.
– Peace of Mind: No IRS penalties for “failure to distribute” at age 72.
The takeaway here is that the RA List is your safety net. It ensures that even if you’re acting on the new laws now, you have a formal window to make sure the “paperwork” catches up with reality.
Conclusion: Key Summary 📝
Navigating the 2025 Required Amendments List doesn’t have to be a nightmare. By focusing on the RMD updates and keeping the 2027 deadline in your sights, you’re already ahead of the curve. To be honest, the most important step is simply starting the conversation with your plan consultant or ERISA attorney now, rather than waiting until the last minute.
Remember, these rules are here to protect the tax benefits for both you and your employees. If you have any specific questions about your plan type or need help interpreting a particular section of Notice 2025-60, feel free to ask in the comments below! I’m always happy to help. 😊
