Proposed Regulations to Update Mortality Tables Delayed

Earlier this year, the IRS released proposed regulations to update the mortality tables that are used to calculate minimum required contributions for single-employer defined benefit (DB) pension plans, as we previously announced. These regulations were proposed to be effective for plan years beginning in 2023 and provided guidance on the use of updated generational and static mortality tables. The IRS also issued Notice 2022-22, which provided mortality tables applicable for valuation dates occurring in 2023 under existing regulations.

At the time, the IRS announced that the mortality tables provided in Notice 2022-22 would apply for purposes of calculating minimum required contributions only for a plan with a plan year that begins in 2022 and has a valuation date in 2023, assuming the proposed regulations would be finalized and effective for plan years beginning on or after January 1, 2023.

The IRS and Treasury are now announcing that the proposed regulations will not be finalized with an effective date in 2023 and that the Notice 2022-22 mortality tables will apply for purposes of calculating minimum required contributions for all plans with a valuation date in 2023.