What you need to know about IRS Notice 2025-60 and retirement plan amendments

By Kimbarley A. Williams, CPA

Maintaining up-to-date plan documents is essential to protecting both your organization and your employees. The IRS regularly updates retirement plan rules, and failing to implement required changes can result in penalties, corrective actions, or even plan disqualification.

IRS Notice 2025-60 outlines the agency’s 2025 Required Amendments List (RA List), which is your roadmap for staying compliant.

So, what’s on the list and why does it matter? Let’s break it down.

Who does this apply to?

The RA List applies to:

• Individually designed plans under section 401(a)
• Individually designed section 403(b) plans
• Pre-approved plans requiring interim amendments

This means that the guidance is relevant to private employers, nonprofit organizations, educational institutions, and governmental entities. If your organization offers retirement benefits through a qualified plan, this notice should be part of your regular compliance review.

Deadlines you need to know

Most plans must adopt amendments appearing on the 2025 RA List by December 31, 2027.
Governmental plans may qualify for additional time under special statutory rules.

In addition to the general RA List deadline, there are separate timelines connected to earlier federal legislation, including the SECURE Act, the SECURE 2.0 Act, and the CARES Act. Those deadlines vary depending on the type of plan:

• Non-governmental plans: December 31, 2026
• Collectively bargained plans: December 31, 2028
• Governmental plans: December 31, 2029
• Public school 403(b) plans: December 31, 2029

Tracking multiple amendment schedules can be challenging, but it is important to determine where your plan fits and to prepare accordingly.

What’s actually changing?

The Required Amendments List is organized into three parts:

• Part A identifies changes that affect most retirement plans.
• Part B includes updates that apply only to plans with unique or specialized provisions.
• Part C would address optional provisions; however, there are none for 2025.

For 2025, the most significant items are as follows:

• Part A: Updates to the Required Minimum Distribution rules resulting from the SECURE Act and SECURE 2.0 Act. These changes address when distributions must begin and how beneficiary payments are structured.
• Part B: New rules related to partnership and trust attribution under section 414(c), effective for plan years beginning January 1, 2025.
• Part C: Nothing new this year.

The amendments listed represent changes that could affect a plan’s qualified status if they are not adopted. That is why the IRS treats these updates as mandatory for sponsors.

What’s NOT on the List?

Notice 2025-60 does not include:

• Guidance issued after the list was prepared
• Optional plan design provisions
• Tax law changes that do not create a risk of disqualification

Annual cost-of-living adjustments are treated as automatically incorporated, even if they are not specifically listed.

What is excluded from the list is not considered “required” for purposes of this notice, although those items may still be relevant to overall plan governance.

What should plan sponsors do?

Plan sponsors can take several practical steps now to remain in compliance:

• Review the 2025 RA List in detail
• Determine which provisions apply to your plan
• Consult the IRS Operational Compliance List to confirm proper implementation
• Coordinate with benefits advisors or ERISA counsel to prepare necessary amendments

The IRS has confirmed that adopting these required amendments by the applicable deadlines will not violate anti-cutback rules. This provides important protection for sponsors as they update their documents.

Bottom line

Staying current with retirement plan rules is a year-round process that requires attention and foresight. IRS Notice 2025-60 offers sponsors clear guidance and ample time to respond. Beginning the review process early and taking a proactive approach will help reduce risk and ensure that your plan continues to meet IRS requirements.

The Boyer & Ritter team is ready to help with any questions about your plan and the new requirements.

About the Author

Kimbarley A. Williams, CPA, is a principal at Boyer & Ritter LLC and is chair of the firm’s Employee Benefit Plan Services Group. Kim has over 20 years of experience providing audit, accounting and tax services to employee benefit plans, business trade associations, charitable organizations, community foundations, and closely held businesses. Contact Kimbarley at 717-761-7210 or kwilliams@cpabr.com.