On November 21, 2022, the IRS issued Notice 2022-62, which is the 2022 Required Amendments List (RA List) for qualified retirement plans. The yearly RA Lists provide changes in retirement plan qualification requirements that could result in disqualifying provisions and require a remedial amendment. A disqualifying provision is a required provision that isn't listed in the plan document, a provision in the document that doesn't comply with the qualification requirements or a provision that the IRS defines as such.
The RA List applies to both 401(a) and 403(b) plans and is divided into two parts: Part A and Part B. Part A lists changes in qualification requirements that will generally require affected plans to be amended. Part B lists changes that would likely not require amendments to most plans but might require an amendment because of an unusual plan provision in a particular plan.
Unlike prior years, there are no Part A or Part B changes this year. The remedial amendment deadline for disqualifying provisions resulting from items on the 2022 RA List is December 31, 2024 (or later, for certain governmental plans). Therefore, plan sponsors should determine whether amendments are necessary for their retirement plan and work with service providers to adopt any such amendment.