IRS Form 15417 – IRS Forms, Instructions, Pubs 2026

IRS Form 15417 – IRS Forms, Instructions, Pubs 2026 – In the world of retirement planning for employees in public schools, tax-exempt organizations, and certain religious institutions, 403(b) plans play a crucial role. These tax-sheltered annuity plans allow eligible workers to save for retirement with tax advantages. However, ensuring a plan qualifies under IRS rules is essential for compliance and tax benefits. This is where IRS Form 15417 comes in—a specialized worksheet designed to determine the status of a 403(b) plan regarding eligibility and participation.

Whether you’re an employer setting up a 403(b) plan, a plan administrator, or an employee curious about your retirement options, understanding Form 15417 can help navigate the complexities of IRS regulations. In this article, we’ll break down what the form is, its purpose, key sections, and how to use it effectively. We’ll draw from official IRS sources to ensure accuracy and provide practical insights for 2026 compliance.

What Is IRS Form 15417?

IRS Form 15417, officially titled “403(b) Plan – Eligibility and Participation Worksheet 1A – Determination of 403(b) Status,” is a diagnostic tool provided by the Internal Revenue Service. Released in April 2023, it’s part of a series of worksheets aimed at helping plan sponsors verify if their 403(b) arrangement meets federal tax code requirements under Section 403(b) of the Internal Revenue Code.

Unlike standard tax forms filed annually, this is a voluntary worksheet used internally or during plan reviews to assess compliance. It’s particularly useful for applications submitted to conform to the IRS’s 2021 Remedial Amendment List (RA List), which outlines updates to plan documents. The form focuses on foundational aspects: employer eligibility, employee participation rules, and universal availability for elective deferrals.

You can download the latest version of the PDF directly from the IRS website: https://www.irs.gov/pub/irs-pdf/f15417.pdf.

The Purpose of Form 15417 in 403(b) Plans

The primary goal of Form 15417 is to evaluate whether a 403(b) plan satisfies eligibility and participation standards, ensuring contributions qualify for tax-deferred treatment. A 403(b) plan, also known as a tax-sheltered annuity (TSA), is available to employees of public schools, certain 501(c)(3) tax-exempt organizations, and ministers. It allows pre-tax salary deferrals, employer contributions, and tax-free growth until withdrawal.

Without proper status determination, a plan risks disqualification, leading to taxable contributions and penalties. The worksheet uses a yes/no format to flag potential issues, with space for explanations on “No” answers. Instructions emphasize that “Yes” responses indicate compliance, while “No” signals problems that may require plan amendments or corrections.

This form is especially relevant for non-church or non-qualified church-controlled organizations (QCCOs), as churches and QCCOs may skip certain sections due to exemptions. It’s integrated with other IRS worksheets, like those for limits on contributions or distributions, for a holistic plan review.

Breaking Down the Key Sections of Form 15417

Form 15417 is structured into four main sections, each addressing critical compliance areas. Below is a detailed overview based on the official form content.

Section I: 403(b) Employer Eligibility Requirements

This section verifies if the sponsoring employer qualifies to offer a 403(b) plan.

  • Is the employer an eligible entity under Treasury Regulation §1.403(b)-2(b)(8)? Eligible employers include public educational institutions, 501(c)(3) organizations, and certain ministers.
  • Does the plan account for employees of related employers when determining income exclusion for contributions?

“No” answers here could indicate the need to restructure the plan or confirm employer status.

Section II: Eligibility of Employees

Focuses on who can participate:

  • Are contributions limited to common-law employees providing services to the employer?
  • Is a “participant” defined as someone with current or past contributions who hasn’t received full distributions?

This ensures only qualified individuals benefit, preventing improper inclusions like independent contractors.

Section III: Universal Availability Requirement for Elective Contributions

A core rule for 403(b) plans is “universal availability,” meaning if any employee can make elective deferrals, all must be allowed (with limited exceptions).

  • Skip if the sponsor is a church or QCCO.
  • Are all employees permitted to defer if any can?
  • Exclusions only as per §1.403(b)-5(b)(4)(ii), such as students or part-time workers under 20 hours/week.
  • For part-time exclusions, does the plan follow the “Once-In-Always-In” (OIAI) rule? Once eligible, employees stay eligible even if hours drop.
  • Does the plan provide effective opportunities for deferrals, including annual elections and notices?

Plans without elective deferrals skip this section. Note: Relief under IRS Notice 2018-95 required amendments by June 30, 2020, for OIAI compliance.

Section IV: Participation Requirements for Non-Elective Contributions

Applies to matching, mandatory, or discretionary contributions:

  • Skip if the sponsor is a church, QCCO, or governmental entity.
  • Does the plan include fail-safe provisions for Section 410(b) coverage failures?
  • Fail-safe language must specify testing and correction methods without employer discretion, fixing rights as of the plan year’s end.

Explanations for “No” answers are required throughout to document issues.

How to Use IRS Form 15417 Effectively?

To complete the worksheet:

  1. Gather Plan Documents: Review your 403(b) plan document, adoption agreement, and related IRS regulations.
  2. Answer Yes/No Questions: Reference specific plan sections for each item.
  3. Explain “No” Responses: Provide details on discrepancies and potential fixes.
  4. Cross-Reference Other Worksheets: If issues arise, consult related forms like Worksheet 6A for contribution limits or Worksheet 15 for distributions.
  5. Seek Professional Advice: Consult a tax advisor or ERISA attorney for complex plans.

The form isn’t filed with the IRS but can support audits or voluntary compliance programs like the Employee Plans Compliance Resolution System (EPCRS).

Why Compliance with 403(b) Eligibility Matters in 2026?

As of February 2026, IRS scrutiny on retirement plans continues, with updates to contribution limits (e.g., $23,000 for elective deferrals in 2026, plus catch-ups). Non-compliance can result in plan disqualification, back taxes, and penalties. Using Form 15417 helps maintain tax advantages, ensures fair participation, and avoids costly errors.

For churches or ministers, special rules apply, such as aggregating service across related organizations. Governmental plans (e.g., public schools) may have exemptions from certain nondiscrimination tests.

Additional Resources and Next Steps

Staying informed about 403(b) rules ensures a secure retirement path. If your plan needs review, start with Form 15417 today to confirm eligibility and participation standards.