2026 has arrived and it’s time to kick-off those New Year’s resolutions! As the calendar turns to 2026, employers and plan sponsors should be reminded of their compliance obligations—this is a fresh opportunity to confirm retirement plans are fully aligned with evolving legal requirements. This year brings several important updates, including the 2025 Required Amendments List (RAL), updated IRS tax tables, and annual TEFRA notice obligations that should be addressed early to avoid year‑end bottlenecks.

Staying ahead of these changes not only minimizes compliance risk but also helps ensure that participants receive accurate information and plan operations run smoothly. In this article, we break down the key updates you need to know as you kick off 2026, along with practical reminders to help keep your plan on track throughout the year.

2025 RAL – What You Need to Know

The IRS issued the 2025 RAL contained in Notice 2025-60, which covers the changes to the required minimum distribution rules.

Background: The RALs establish the date by which plan amendments must be made for changes contained on the lists in order for a plan to maintain its tax-qualified status. All RALs apply to both individually designed plans qualified under Internal Revenue Code (Code) § 401(a) and individually designed plans that satisfy the requirements of Code § 403(b).

Generally, the RAL will not include a change to the requirements until guidance regarding the change (including any model amendments) has been provided via regulations or in other guidance published by the IRS. However, the IRS may include items in other situations, for instance, when a statutory change is enacted, and it is anticipated that no guidance will be issued.

2025 RAL: The 2025 RAL includes the 2024 Final Regulations on changes to the Required Minimum Distribution (RMD) rules, which include the increased Required Beginning Date ages and the changes to the lifetime payments (stretch IRA) for defined contribution plans. The 2025 RAL includes a footnote stating that the IRS anticipates including the SECURE 2.0 Roth catch-up for higher earners on the 2027 RAL.

Deadline: In general, plan sponsors must adopt any item on the RAL by the end of the second calendar year following the year the list is published. However, if later, the amendment date for governmental plan sponsors generally is extended to 90 days after the close of the third regular legislative session of the legislative body with authority to amend the plan that begins on or after the date of issuance of the RAL.

Impact: For the 2025 RAL changes, plans have until December 31, 2027, to amend the plan document. Notice 2024-2 provided that governmental plans had until December 31, 2029, to amend governmental plans. It is unclear whether governmental plans will have the “later of” December 31, 2029, or the “90 days after the close of the third regular legislative session of the legislative body with authority to amend the plan that begins on or after the date of issuance of the RAL.” More guidance on the applicable deadline would be welcome.

Updated Tax Tables

The IRS has released the updated tax tables for 2026 in Publication 15-T.

To ensure accurate federal tax withholding, retirement systems and other plan sponsors should ensure that any necessary programming updates to incorporate the updated tax tables are made.

Updated Indexed Limits

On November 13, 2026, the IRS released updated indexed limits to take effect on January 1, 2026. To assist plan sponsors, Ice Miller’s updated Maximum Dollar Limits chart lists the cost-of-living adjustments to retirement plan limitations for the years 2016 through 2026. We hope that this chart (which includes the adjusted limits, as well as Social Security and Medicare contribution rates, and taxable wage bases for the past ten years) serves as a helpful reference tool.

Annual TEFRA Notice

Annually, retirement plans are required to provide benefit recipients an opportunity to update their federal income tax withholding for benefit payments that are not eligible for rollover distributions (this is known as the TEFRA notice).

For periodic and non-periodic payments, the recipient of an employer pension or annuity benefit is entitled to choose not to have income tax withheld from retirement plan payments (so long as the payments are not eligible rollover distributions). For a detailed discussion of federal withholding tax, visit Publication 575 Pension and Annuity Income (2024), pp. 9-10. The withholding election remains in effect until the recipient changes or revokes the withholding election in place.

For periodic payments, unless the recipient chooses “no withholding,” the annuity or similar periodic payment will be treated like wages for withholding purposes. Therefore, if the payee does not provide a completed withholding certificate (Form W-4P), or if the payee provides an invalid withholding certificate, federal tax will be withheld as if the payee is single with no adjustments.

Thus, at least annually, retirement plans must notify benefit recipients of the opportunity to change their withholding elections. As provided in Section 8 of Publication 15-A, Employer’s Supplemental Tax Guide (Supplement to Pub. 15, Employer's Tax Guide), see Publication 15-T, Federal Income Tax Withholding Methods, for the appropriate computational method to figure federal income tax withholding on periodic payments. To assist taxpayers, the IRS provides a Tax Withholding Estimator for use by taxpayers in estimating the appropriate withholding for federal income taxes.

If you would like to discuss the impact of any of these developments, or need assistance with your plan’s new year’s resolutions, please do not hesitate to contact Audra J. Ferguson, Robert L. Gauss, Nicole Giambarrese, Lisa Erb Harrison, Lindsay Knowles, Rachel Mattingly Phillips, Stanley D. Prybe, Shalina Ann Schaefer, or the Ice Miller Employee Benefits lawyer with whom you regularly work.

This publication is intended for general information purposes only and does not and is not intended to constitute legal advice. The reader should consult with legal counsel to determine how laws or decisions discussed herein apply to the reader's specific circumstances.