Restatement windows for 403(b) and DC plans

Just wondering...

The 2-year restatement window for 403(b) plans is currently scheduled to open 1/1/2025.

If the restatement window for 401(k) plans opens 1/1/2026,then the two will overlap. Originally, (in a galaxy long, long ago and far, far away) I seem to recall that the "regular" pre-approved plan cycles were going to be timed such that they would not overlap, but I'm not certain of that.

This could create some challenges.

Do you know if anyone has suggested to the IRS (document providers, ARA, etc.) that the 2-year DC Cycle 4 restatement window not open until 2027, to avoid this overlap? And if so, even unofficially, was the IRS at all receptive to the suggestion?

Published in today’s Internal Revenue Bulletin, Notice 2024-2 addresses some aspects of remedial-amendment dates.

Notice 2024-2, 2024-2 I.R.B. 316, 332-333 [including Q&A-J1] (Jan. 8, 2024), available at https://www.irs.gov/pub/irs-irbs/irb24-02.pdf.

But the Notice does not further address the details for using IRS-preapproved documents.

Yeah, I saw that - thanks. As things stand now, it would be my goal to have all our 403(b) plans restated by 12/31/2025, so that 2026 could start with a clean slate, in a manner of speaking, for restating 401(k) plans. But things rarely work out so well. I'd also like the SECURE amendments to be done by 12/31/2025, in spite of the extended deadline. But a lot could change between now and then!

Looks like I was worrying over nothing (or just plain wrong...) Restatement period for Cycle 4 is likely to be from early 2027 to early 2029. Hurray!

For such a restatement that might be done in, for example, December 2028 or January 2029, how far retroactive in tax law changes does the remedial-amendment effect go?

Honestly, I haven't bothered to figure it out yet. I fully plan to be retired by then, so selfishly, it'll be someone else's problem. I did see something about this somewhere, but I just skipped over it, so I don't know what it said...