Cycle 3 Plan Restatement Reminder

Approximately every six years, the IRS requires most company-sponsored retirement plans to update their plan documents through a process called “restating” the document. The IRS-announced Cycle 3 restatement window began August 1, 2020, with a final deadline, coming soon, of July 31, 2022.

Key Considerations

  • A restatement is a complete re-writing of the plan document. It incorporates changes from any mandatory or voluntary amendments that may have been adopted since the last time the document was re-written.
  • While some plan sponsors may choose to voluntarily restate their plans from time to time for various reasons, the upcoming plan restatement is mandatory.
  • With the looming July 31, 2022 deadline, most employers have already updated their plan documents for Cycle 3.  If not, now is the time to focus on updating 401(k) and other plans, including profit-sharing, money purchase, and employee stock ownership plans, to the Cycle 3 versions.
  • Plans that do not adopt a restated plan document by July 31, 2022, will be out of compliance and must work with their service providers to correct the document failure by following the rules outlined in the IRS voluntary correction program known as the Employee Plans Compliance Resolution System (EPCRS).  

TRI-AD will complete all of the Cycle 3 updates for our clients on or before July 31, 2022. 

Please contact your TRI-AD Client Service Manager with any questions you may have about the Cycle 3 restatement. For other compliance deadlines, please see our Fiduciary Compliance Calendar.


TRI-AD and our Associates’ suggestions or recommendations shall not constitute legal advice. No content on our website can be construed as tax or legal advice and TRI-AD may not be considered your legal counsel or tax advisor. Clients are encouraged to consult with their tax advisor and/or attorney to determine their legal rights, responsibilities, and liabilities. This includes the interpretation of any statute or regulation, federal, state, or local; and/or its application to the clients’ business activities.