What is happening?

The IRS requires all pre-approved 403(b) plans to be restated to updated Cycle 2 documents to reflect current regulations and guidance.

Key Deadline

December 31, 2026 – Plans must be fully restated and adopted by this date.

Why it matters

• Aligns plan documents with current regulations
• Maintains reliance on IRS approval
• Ensures consistency with plan operations

Who is impacted?

Employers with pre-approved 403(b) plans, including public schools and tax-exempt organizations.

Consequences of Missing Deadline

• Loss of IRS reliance
• Potential plan disqualification risk
• Need for IRS correction programs (e.g., VCP)
• Increased audit exposure

Advisor Action Steps

• Confirm your clients plan document type and provider – MetLife does not provide document services to all clients, verify with the plan sponsor.
• Work with Plan Sponsor to ensure execution before deadline

Advisor Talking Points

• This is a required compliance update, it is not optional
• Opportunity to review your plan design
• Advisor coordination ensures smooth adoption

Bottom Line

Cycle 2 restatements are a critical compliance requirement. Proactive execution helps mitigate risk and strengthen client relationships.