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We've covered the issue before that the effective date of the Plan can pre-date the effective date of the sponsoring entity.

You don't NEED to restate, but you do need to make sure the plan is fully up to date with law and regulations (even if interim amendments are not yet due) and the best way to ensure that is to restate and include the plan provider's amendment for terminating plans.

If the entity required to file the 5500 is also required to file at least 250 returns of any type, mandatory electronic filing of the 5500-EZ applies. The CPA is incorrect.

What purposes does the sponsor want the amendment to be retroactively effective for? If for 401(a)(4) or 410(b), you can do it as a 1.401(a)(4)-11(g) amendment, although you indicated that there was no coverage or nondiscrimination failure that would need correcting. If for 401(a)(26), you can do it as a 1.401(a)(26)-7(c) amendment, which operates under similar rules to -11(g). If for minimum funding/maximum deduction purposes, too late. The deadline to adopt a 412(d)(2) amendment for 2021 was March 15, 2022. If none of the above: then just make the amendment effective in 2022, and give them credit for 2021 for accrual service.