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ARTICLE · 21 JULY 2021

IRS Issues Updated EPCRS Revenue Procedure

Perkins Coie LLP
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The Internal Revenue Service released updates to its Employee Plans Compliance Resolution System ("EPCRS") in Revenue Procedure 2021-30.

United StatesEmployment and HR
Cristopher D. Jones
Cristopher D. Jones

The Internal Revenue Service released updates to its Employee Plans Compliance Resolution System ("EPCRS") in  Revenue Procedure 2021-30.  Key changes to the EPCRS include:

  • Extending the self-correction period for significant operational failures from two to three years, effective July 16, 2021;
  • Eliminating the requirement that retroactive plan amendments for self correction benefit all plan participants, effective July 16, 2021;
  • Eliminating the ability to make anonymous submissions but allowing anonymous no-cost pre-submission conferences to discuss potential VCP submissions, effective January 1, 2022;
  • Extending the sunset date for the safe harbor correction method for missed deferral failures in plans with automatic contribution features from December 31, 2020 to December 31, 2023, effective January 1, 2021;

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