IRS Updates Determination Letter and VCP Submission Requirements

The Internal Revenue Service (IRS) has issued Revenue Procedure (Rev. Proc.) 2026-4, which includes updates to determination letter submission procedures and user fees associated with Employee Plans Rulings and Agreements. In addition to minor non-substantive changes, updates from the prior year Rev. Proc. 2025-4 include the following. 

• All Form 5300 series determination letter requests must now be submitted electronically on www.pay.gov.
• User fees for letter rulings and determination requests will generally not be refunded if there is an omission of material facts in the original submission that, had Employee Plans Rulings and Agreements known of the omission at the time of submission, would have resulted in it declining to rule on all the issues.
• Determination letter filing fees have increased pursuant to Appendix A.

Also, regular submissions under the IRS Voluntary Correction Program are subject to the following fees based on end of year plan assets reported on the most recently filed Form 5500 series return.

• $2,000 for a plan with assets of $500,000 or less (up from $1,500).
• $3,500 for a plan with over $500,000 in assets but less than $10,000,000 (up from $3,000).
• $4,000 for a plan with over $10,000,000 in assets (up from $3,500).

The effective date of the Revenue Procedure is January 1, 2026.