On December 4, 2025, the U.S. Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) issued Notice 2025-60, which outlines the 2025 Required Amendments List (RA List) for qualified defined benefit (DB) and defined contribution (DC) plans and 403(b) plans. The RA List provides the plan amendment deadline to reflect legislative, regulatory, and guidance changes appearing on the list affecting the requirements for such plans and applies to both individually designed plans and pre-approved plans.¹

In general, any given year’s RA List consists of those changes for which the IRS has provided regulatory or other guidance on such changes (or anticipates no guidance is necessary) and with which plans must comply in operation during the calendar year in which the list is published.

The amendments on the 2025 RA List that apply to most plans pertain to provisions from the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act) and the SECURE 2.0 Act of 2022 (SECURE 2.0 Act) that relate to changes in the required minimum distribution (RMD) rules.

The RA List is an annual list of changes in statutory and administrative requirements that plans may need to adopt to maintain their tax-qualified or tax-advantaged status. The RA List is divided into three parts and includes the following language:

• “Part A includes changes in requirements that (1) generally would require an amendment to most plans or to most plans of the type affected by the changes, and (2) do not relate to optional plan provisions previously adopted.”
• “Part B includes changes in requirements that (1) the Treasury Department and the IRS anticipate will not require amendments to most plans but might require an amendment because of an unusual plan provision in a particular plan, and (2) do not relate to optional plan provisions previously adopted. For example, if a change affects a particular requirement that most plans incorporate by reference, Part B would include that change because a particular plan might not incorporate the requirement by reference and, thus, might include language inconsistent with the change.”
• “Part C includes changes in requirements that relate to optional plan provisions previously adopted.”

Certain adjustments, such as cost-of-living increases to dollar limits or updates to IRC section 417(e) interest rates and mortality tables, are considered part of the annual RA List for the year in which the changes are effective even if not explicitly mentioned. The Treasury Department and IRS expect that few plans include language requiring amendments due to these changes.

2025 RA List required changes that apply to most plans (Part A)

The following changes will require an amendment to most plans:

Required minimum distributions (RMDs). Sections 114 and 401 of the SECURE Act amended the RMD rules under IRC section 401(a)(9). Section 114 increased the RMD age (with further updates by Section 107 of the SECURE 2.0 Act), while Section 401 revised the post-death RMD requirements for designated beneficiaries of DC plans. The Treasury Department and IRS published final regulations on July 19, 2024, to clarify and implement these changes.

• RMD age—affecting both DC and DB plans. Figure 1 illustrates how the SECURE Act and SECURE 2.0 Act changed the RMD ages. The final RMD regulations do not address the ambiguity in the RMD age for individuals born in 1959 who take distributions after December 31, 2022. This issue is addressed in the proposed RMD regulations that were released at the same time as with the final regulations. Notice 2025-60 provides that changes in the proposed regulations will be included in a future RA List once those regulations are finalized.

• Observation. Plans may not retain an earlier RMD age. Plans can, however, require participants to start distributions at an age earlier than the new required beginning date (RBD) based on the increased ages shown in Figure 1. For example, plans could require that distributions start at age 70½ or at normal retirement age, but distributions made earlier than the new statutory RBD are not considered RMDs. Note that the annuity starting date for DB plan distributions that start before the statutory RBD in the form of an annuity that would satisfy the RMD requirements will generally be treated as the RBD for purposes of satisfying the RMD requirements. Plans that choose to retain a mandatory start date earlier than the statutory RBD should review how these provisions are stated in the plan document, summary plan description, and all participant communications.
• Post-death RMD rules for designated beneficiaries—affecting DC plans. The SECURE Act also changed the RMD rules to require that, in general, a deceased participant’s benefit in a DC plan must be entirely paid to a designated beneficiary by the end of the calendar year that includes the 10th anniversary of the participant’s death (the 10-year rule). The benefit could be made over the beneficiary’s life or life expectancy if the beneficiary is an eligible designated beneficiary.

Please refer to our review of the final RMD regulations and proposed regulations for more details about the above changes.

2025 RA List required changes related to unusual plan provisions that do not apply to most plans (Part B)

The following changes may require an amendment based on a plan’s unusual provisions.

• Partnership and trust attribution rules. The Treasury and IRS published final regulations on December 30, 2024, extending the “partnership and trust attribution rules to the determination of whether a parent-subsidiary controlled group exists under section 414(c) of the Code (trades or businesses under common control). The change applies to plan years beginning on or after January 1, 2025.”

2025 RA List required changes related to previously adopted optional provisions (Part C)

There are no required amendments in this category.

Plan amendment deadlines

For each year’s RA List, the plan amendment deadline to reflect legislative, regulatory, and guidance changes appearing on that year’s RA List is the end of the second calendar year following the year during which the RA List is published. Accordingly, the general deadline for plan amendments under the 2025 RA List is December 31, 2027 (the deadline may be later for governmental plans).

However, the deadlines for required and discretionary amendments under the SECURE Act; the SECURE 2.0 Act; certain provisions of the Bipartisan American Miners Act of 2019 (Miners Act); the Coronavirus Aid, Relief, and Economic Security Act (CARES Act); and the Taxpayer Certainty and Disaster Tax Relief Act of 2020 are provided in IRS Notice 2024-2 and may be earlier than December 31, 2027. For example, plan amendments to comply with these laws must generally be adopted by December 31, 2026, for qualified plans that are not governmental or collectively bargained, as well as for 403(b) plans not maintained by a public school. A summary of all the amendment deadlines for these laws can be found here.

Please contact your Milliman consultant with any questions.

¹ The RA List plan amendment deadline is referred to as the “remedial amendment period deadline” for individually designed plans and the “interim amendment deadline” for pre-approved plans. Effective November 21, 2023, Revenue Procedure 2023-37 provides that these deadlines will be aligned.