Schedule R

Am I understanding correctly, when filing the Form 5500, the Schedule R is now required for plans even without distributions in the plan year? This just to accommodate the new compliance questions?  2022 instructions for the Schedule R listed additional exceptions for plans without distributions that seem to have been left off of the 2023 instructions. 

I suggest the correct way to look at it is a Schedule R is required whenever a plan must report information on any line on the form.  The Schedule R has an array of topics that apply to specific types of plans or to specific circumstances.  It is possible for a Form 5500 not to be required to attach a Schedule R, but this has become unlikely.  The requirement to report the opinion letter number for a pre-approved plan will by itself cause the vast majority of plans to have to attach a Schedule R.