The IRS has extended the deadline for plan sponsors of qualified retirement plans and IRAs to make amendments under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) and the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Relief Act) that were not extended under prior IRS guidance. In Notice 2022-45 the IRS provides that qualified retirement plans (other than governmental plans) and IRAs have until December 31, 2025, to adopt amendments related to coronavirus-related distributions and plan loan relief under the CARES Act, and qualified disaster distributions under the Relief Act. Plan amendment deadlines are amended as follows:

Before this extension, the deadline for amendments to qualified retirement plans (other than governmental plans) and IRAs was the end of the first plan year beginning on or after January 1, 2022 (December 31, 2022 for calendar year plans). The IRS previously released guidance in Notice 2022-33 (as we summarized here) which provided an extension for other amendments related to changes under the SECURE Act for required minimum distributions and qualified birth or adoption distributions, the Miners Act changes for distributions from defined benefit plans and 457(b) plans and CARES Act relief for 2020 required minimum distributions.

ESsentials: With this deadline extension, plan sponsors should generally be able to adopt all necessary CARES Act and SECURE Act amendments on a single date if desired. However, plan sponsors may want to amend now for these changes in order to memorialize operations in the event of any questions and to minimize the need to remember to amend in a future year.