By Brett Sinsabaugh, CPA, CCA, Partner
The IRS has issued its 2025 Required Amendments List (RA List), outlining changes that may require updates to 403(b) retirement plan documents. This annual guidance helps ensure plans remain compliant with IRS qualification and Section 403(b) requirements.
What Should 403(b) Plan Sponsors Do Now?
For 403(b) Plan sponsors of individually designed and pre-approved plans, which commonly include 501(c)(3) tax-exempt organizations:
- December 31, 2027, is generally the deadline to adopt required amendments
- This applies to both individually designed and pre-approved 403(b) plans
- Amendments may be adopted retroactively during the IRS-approved remedial amendment period
Even though the amendment deadline is still a few years away, proactive planning is a best practice.
Nonprofit plan sponsors should consider:
- Confirming whether their 403(b) plan is individually designed or pre-approved
- Checking in with their plan provider, TPA, or legal advisor to understand how the 2025 RA List applies to their plan
- Ensuring amendment responsibilities are clearly assigned, especially if relying on a document provider
- Documenting compliance efforts for governance and audit purposes
Early awareness reduces last-minute stress and helps ensure ongoing compliance.
Keiter’s ERISA audit team monitors new and changing regulations to keep your plan compliant. Contact your Keiter Opportunity Advisor if you have any questions specific to your plan. Email | Call: 804.747.0000
About the Author
Brett Sinsabaugh, CPA, CCA, Partner
Brett’s client focus is primarily in the real estate and construction industry. He also provides financial statement audit, assurance, and employee benefit plan audit services to privately-held businesses in the manufacturing, retail and distribution, and technology industries, as well as membership organizations and trade associations. Brett is a member of the Firm’s Employee Benefit Plan audit team and Real Estate and Construction industry team.
More Insights from Brett SinsabaughThe information contained within this article is provided for informational purposes only and is current as of the date published. Online readers are advised not to act upon this information without seeking the service of a professional accountant, as this article is not a substitute for obtaining accounting, tax, or financial advice from a professional accountant.
