IRS 2025 Required Amendments List Extends Deadline for SECURE RMD Changes

The IRS 2025 Required Amendments List (RA List) contained in Notice 2025-60 (Dec. 2025) outlines key plan amendment requirements for qualified retirement plans and Section 403(b) arrangements. While the list is relatively concise this year, it carries significant implications for plan sponsors, particularly with respect to required minimum distribution (RMD) changes under the SECURE 1.0 and SECURE 2.0 Acts.

Our retirement plan specialists have analyzed the RA List to explain what it is, and what sort of changes were included in the most recent. Plan sponsors should use 2026 to implement these changes to comply with the December 31, 2027 deadline.

Understanding the Required Amendments List

The RA List is the IRS’s annual reminder of changes in tax law or guidance that require formal plan amendments. When a change appears on the list, sponsors of affected plans must adopt conforming amendments by the end of the second calendar year following the year in which the list is issued. For the 2025 RA List, that means amendments must be adopted no later than December 31, 2027.

This deadline applies to both individually designed plans and preapproved plans (through interim amendments). Note, the RA List does not alter deadlines for discretionary plan design changes, which generally must be adopted by the end of the plan year in which the change becomes effective

The RA List is organized into three parts:

• Part A: Changes requiring amendments to most plans and not tied to optional provisions previously adopted.
• Part B: Changes that may affect only certain plans with unusual provisions.
• Part C: Changes relating to optional plan provisions previously adopted

For the 2025 list, only Parts A and B contain items; no further attention is required on Part C.  

SECURE 1.0 and 2.0 RMD changes take center stage

The most notable inclusion is the incorporation of final regulations issued in 2024 addressing RMD changes under SECURE 1.0 and certain provisions of SECURE 2.0.

SECURE 1.0 increased the required beginning date (RBD) age to 72 for participants born on or after July 1, 1949, and before 1951, and significantly limited the ability of non-spouse beneficiaries to “stretch” distributions over their lifetimes. The final regulations also incorporate some of SECURE 2.0’s RMD changes, including further increases in the RBD age to 73 for participants born after 1950 and to 75 for those born after 1959.

Other SECURE 2.0 RMD changes not covered by the 2024 final regulations will appear on a future RA List once finalized.

Extended amendment deadlines for RMD provisions

In Notice 2024-2 (Jan. 2024), the IRS previously set December 31, 2026 as the general amendment deadline for SECURE 1.0 and 2.0 changes. However, the 2025 RA List effectively extends the deadline for SECURE 1.0 RMD changes and certain SECURE 2.0 RMD provisions to December 31, 2027.

This extension may have been granted because the final RMD regulations became applicable in 2025 and that the RA List typically includes only those changes with which plans must operationally comply during the year the list is issued.

The IRS also signaled that the SECURE 2.0 Roth catch-up contribution mandate for high earners is expected to appear on the 2027 RA List, which would provide a December 31, 2029 amendment deadline.

Part B: Controlled Group Attribution Rules

Part B includes final regulations extending partnership and trust attribution rules for determining participant-subsidiary controlled groups under IRC Section 414(c). These rules apply for plan years beginning on or after January 1, 2025. Although IRS anticipates that relatively few plans will require amendments, sponsors whose documents do not incorporate controlled group rules by reference should review their plan language to determine whether amendments are necessary by December 31, 2027.

Additional considerations

The RA List automatically encompasses periodic updates such as cost-of-living adjustments and applicable interest and mortality tables under IRC Section 417(e)(3). Plans that do not incorporate these provisions by reference may also require amendment.

Finally, while collectively bargained and governmental plans often receive extended amendment deadlines, the 2025 RA List does not clarify whether previously granted extensions for SECURE-related changes apply to the RMD provisions now included. Further IRS guidance may be forthcoming.

Bottom Line

The 2025 RA List may appear limited in scope, but its inclusion of SECURE-related RMD changes, and the corresponding amendment extensions, makes it a critical compliance checkpoint. Plan sponsors should coordinate with counsel and document providers to ensure timely amendments and confirm that operational practices align with final regulations now in effect.

For plan compliance and assistance with changes from the 2025 RA List, fill out the form on this page.

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