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The Internal Revenue Service (IRS) requires plan sponsors who use a pre-approved 403(b) plan document to be updated on a regular restatement cycle. The current Cycle 2 restatement is now in effect and all 403(b) plans that use a pre-approved plan document must adopt the Cycle 2 restated plan document by December 31, 2026. The restatement should incorporate changes from the SECURE Act, CARES Act, and SECURE 2.0, among other regulatory updates.
What Cycle 2 includes
The Cycle 2 restatement is the IRS-mandated update to your underlying 403(b) pre-approved plan document. The new document addresses updated laws and IRS guidance, including, but not limited to:
changes regarding permitted mid-year reductions or suspensions of safe harbor nonelective contributions in certain circumstances;
elimination of certain safe harbor notice requirements for plans that provide for safe harbor nonelective contributions and new provisions for the retroactive adoption of safe harbor status for those plans;
amended definitions of qualified matching contributions (QMACs) and qualified nonelective contributions (QNECs);
changes regarding in-plan Roth conversions;
changes to hardship distribution rules;
rules regarding 403(b) plan termination and distribution of individual custodial accounts upon plan termination;
new in-service distribution options; and
changes to required minimum distribution (RMD) rules.
These laws and regulations are not separate plan elections; they are mandatory provisions that must be reflected in the document unless the law provides an exception.
How this compares to your 2020 restatement
2020 (Cycle 1): Your plan was restated onto the first IRS pre-approved 403(b) plan document template. During that restatement, your plan document was updated to incorporate standardized IRS-approved language, law and guidance in effect at that time.
2026 (Cycle 2): Your plan documents must be restated using the Cycle 2 pre-approved plan document template, which incorporates guidance from SECURE, CARES, SECURE 2.0, including changes to required minimum distribution rules, new contribution and eligibility provisions, and other operational requirements.
Cycle 2 is the mechanism that formally consolidates these changes into your governing plan document.
What you need to do
No signatures are required today, but you must adopt the Cycle 2 restatement or provide your documents to Corebridge by the IRS deadline. To stay on track:
Monitor communications from Corebridge. You will receive advance notice, draft documents, final documents for adoption, and follow-up reminders. Each communication will specify whether action is required.
Review and execute restated documents when requested. When you receive the Cycle 2 restatement package, review it according to your internal governance process and complete the adoption steps by the stated deadline.
Coordinate with your internal and external partners. Make sure all relevant parties (for example, HR, benefits, legal, third-party administrators) know that a mandatory restatement is in process and understand their responsibilities.
- Keep contact information current. Ensuring that Corebridge has accurate contact details helps prevent missed communications and delays.
Frequently asked questions
No. For plans using a Corebridge preapproved 403(b) plan document, adoption of the Cycle 2 restatement by December 31, 2026, is a requirement of the IRS restatement program
No. SECURE 2.0 is one of several laws being incorporated. Cycle 2 also includes required provisions from the SECURE Act, CARES Act, and other guidance issued after your 2020 restatement.
If your company adopted your Plan prior to 2025, the Plan did not use the most recent IRS pre-approved template. All plans on Corebridge’s document must be restated using the latest IRS pre-approved template no later than December 31, 2026.
Yes. You should expect informational notices, delivery of draft and final documents, and reminders if action is needed. Each communication will clearly indicate next steps and timing.
If the plan does not adopt the Cycle 2 document on time, the plan may lose reliance on the IRS opinion letter and could be treated as failing to satisfy applicable document requirements. This may require corrective action and could impact the plan’s tax favored status.
If you receive recordkeeping services from Corebridge, or if we still manage some plan assets, we need you to send us a copy of your Cycle 2 restated plan documents.
Without an updated restated document on file, Corebridge will not be able to assist with contracted services such as administration and compliance support.
Your existing plan may state the document provider, or you can contact your legal counsel, third-party administrator, or prior provider. If there is uncertainty about whether Corebridge provides your plan document services, you can contact our plan document team at CBPlanDocRestatements@corebridgefinancial.com.
Reach out with questions
If you have questions, please contact your Corebridge representative, financial advisor or the Corebridge Plan Document team at CBPlanDocRestatements@corebridgefinancial.com.
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