Vorys Benefits Brief: Treasury and IRS Release Updated Retirement Plan Correction Program
On October 22, 2026, the Department of the Treasury and the Internal Revenue Service released the latest version of the Employee Plans Compliance Resolution System (EPCRS). Revenue Procedure 2026-34 modifies and supersedes Revenue Procedure 2021-30, as well as three notices—Notice 2023-43, Section II.I of Notice 2024-2, and Notice 2024-77—which provided interim guidance on changes under the SECURE 2.0 Act. The new guidance is generally effective immediately.
Retirement plans are complex and, despite best efforts, errors can occur. EPCRS provides a framework for plan sponsors to correct many types of errors and, in most cases, preserve the tax-qualified status of the plan. The updated EPCRS covers qualified defined contribution plans (including 401(k) plans), qualified defined benefit plans, section 403(b) plans, Simplified Employee Pension (SEP) arrangements, and SIMPLE IRA plans. The updated EPCRS continues to offer three methods of correction: an expanded Self-Correction Program, Voluntary Correction Program, and Audit Closing Agreement Program. The new revenue procedure incorporates certain changes required by the SECURE 2.0 Act and makes numerous technical changes to EPCRS.
Next Step for Plan Sponsors
Plan sponsors should use the updated EPCRS when addressing newly identified errors and should review any corrections that are already in process but have not yet been completed. For each correction, plan sponsors should confirm that:
- the proposed correction method is permitted under Revenue Procedure 2026-34;
- all applicable correction program requirements are satisfied; and
- appropriate documentation of the error and correction is prepared and retained.
Plan sponsors that identify or are in the process of correcting retirement plan errors should consult with legal counsel to determine the appropriate correction method and ensure compliance with the updated EPCRS.
Contact Legal Counsel
For questions or additional information about this Vorys Benefits Brief and its application, consult with legal counsel.
