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ARTICLE · 10 NOVEMBER 2026

IRS Updates The Employee Plans Compliance Resolution System

K&L Gates
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The IRS has issued Revenue Procedure 2026-34, fundamentally updating the Employee Plans Compliance Resolution System (EPCRS) with immediate effect. This comprehensive update incorporates retirement plan correction principles from the SECURE 2.0 Act of 2022, expanding self-correction options, clarifying retroactive amendment procedures, and providing more flexible approaches to overpayment recovery.

United StatesEmployment and HR
Elliot W. DiGioia
Elliot W. DiGioia
Lauren M. Crossett
Lauren M. Crossett

At a Glance

On 22 October 2026, the Internal Revenue Service issued Revenue Procedure 2026-34, updating the Employee Plans Compliance Resolution System (EPCRS). Sponsors analyzing or processing retirement plan corrections should confirm that any corrective actions align with the updated correction procedures. The long-awaited EPCRS update incorporates retirement plan correction principles and guidance previously established by SECURE 2.0 Act of 2022 and is effective immediately. It supersedes Revenue Procedure 2021-30, IRS Notices 2023-43 and 2024-77, as well as section II.I of Notice 2024-2.

Key EPCRS Updates

Expanded Self-Correction

EPCRS incorporates the SECURE 2.0 Act’s self-correction of “eligible inadvertent failures.” Self-correction continues to require the plan sponsor to maintain established compliance practices and procedures reasonably designed to promote overall compliance with the Internal Revenue Code of 1986, as amended (Code) and to timely complete the

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