Your Essential Guide to the Cycle 4 Restatement
For retirement plan sponsors, keeping a plan document up to date is an important part of maintaining a compliant 401(k) or other defined contribution plan. As retirement plan laws and regulations change, plan documents need to be updated to reflect those requirements. RPCSI can help plan sponsors navigate these updates, understand what changes may apply to their plan, and stay on track with important deadlines.
Cycle 4 is happening now, and the employer adoption window is officially open. But there is another important deadline plan sponsors need to know about: the December 31, 2026 deadline for certain SECURE 2.0 amendments.
Understanding what Cycle 4 means, how it differs from the SECURE 2.0 deadline, and what you can do now can help you stay organized and prepared.
What Is a Required Restatement?
A restatement is an update to a retirement plan document that brings the document in line with current laws and IRS requirements.
Pre-approved retirement plans, including many 401(k) and other defined contribution plans, go through regular update cycles. During these cycles, plan providers update their documents to reflect changes in retirement plan laws and regulations. Employers then adopt the updated document for their plans.
For plan sponsors, a restatement does not necessarily mean that the way your plan operates will change. Instead, it is an opportunity to make sure your written plan document reflects the rules and provisions that apply to your plan.
What Plan Sponsors Need to Know About Cycle 4
Cycle 4 is the fourth remedial amendment cycle for pre-approved defined contribution plans. The updated documents account for changes in retirement plan laws and regulations included on the IRS's applicable cumulative list.
With the employer adoption period open, plan sponsors have time to work with their retirement plan providers and prepare for the updated documents.
One of the most important dates to keep in mind is:
September 30, 2028: The deadline for employers to adopt their updated Cycle 4 pre-approved defined contribution plan document.
While 2028 may seem far away, there is another deadline that comes much sooner.
Cycle 4 vs. the SECURE 2.0 Amendment Deadline
The December 31, 2026 SECURE 2.0 amendment deadline is separate from the Cycle 4 restatement deadline.
This is an important distinction for plan sponsors. Certain SECURE 2.0 provisions require plan amendments before the full Cycle 4 restatement documents are finalized. This means plan sponsors may need to address SECURE 2.0 changes now, even though the deadline for adopting the full Cycle 4 restatement is not until 2028.
In other words, your plan may have two different document-related deadlines:
December 31, 2026: Certain SECURE 2.0 amendments must be adopted.
September 30, 2028: The Cycle 4 restatement must be adopted.
Depending on your plan, your provider may provide a separate amendment for applicable SECURE 2.0 provisions. This allows those required changes to be added to your current plan document before the full Cycle 4 restatement is ready. Plan sponsors should work with their retirement plan professional to understand which provisions apply to their specific plan and what needs to be completed by each deadline.
Keeping track of both deadlines now can help prevent last-minute work and make the overall restatement process easier to manage.
How Plan Sponsors Can Prepare for Cycle 4
You don't need to wait until the Cycle 4 deadline to start preparing. Reviewing your current documents now can help make the process smoother when your updated plan document is ready.
Start by reviewing your current 401(k) or defined contribution plan document and any amendments that have been made since the last restatement. This gives you and your retirement plan professional a clearer picture of your plan's current provisions.
It can also help to gather:
Your current plan document
Previous amendments
Records of any plan design changes
Other documents related to your plan's provisions
From there, review the updates that apply to your plan and determine whether any additional plan design decisions need to be addressed. This is also a good opportunity to review your current plan provisions and make sure they still align with how your business and retirement plan are structured today. Identifying any questions or potential changes early can help make the restatement process more straightforward.
Once required documents and amendments are completed, make sure they are properly signed, dated, and maintained with your plan records. Keeping these documents organized can make it easier to manage future retirement plan requirements.
Stay Prepared for Cycle 4
Cycle 4 is an important part of keeping your retirement plan document current, but it is not the only deadline plan sponsors need to track. With the December 31, 2026 SECURE 2.0 amendment deadline and the September 30, 2028 Cycle 4 adoption deadline, understanding what needs to be completed and when is an important part of managing your plan.
RPCSI can help guide you through the restatement process and stay on top of your plan's ongoing requirements. Contact RPCSI to learn more about Cycle 4 and how we can support your retirement plan.
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