IRS Form 8717-A – In the complex world of employee retirement plans, ensuring compliance with IRS regulations is crucial for plan providers and sponsors. One key aspect involves obtaining opinion letters for pre-approved plans, which confirm that the plan documents meet IRS requirements. If you’ve submitted an application for such a letter but paid an insufficient user fee, IRS Form 8717-A comes into play. This form allows you to make additional payments to correct the fee shortfall. In this SEO-optimized article, we’ll break down everything you need to know about Form 8717-A, including its purpose, user fees, filing instructions, and more, based on the latest IRS guidance as of 2026.
What Is IRS Form 8717-A?
IRS Form 8717-A, titled “User Fee for Employee Plan Opinion Letter Request,” is a specialized form used by plan providers to submit additional user fees for applications related to opinion letters on pre-approved employee retirement plans. These plans typically fall under sections 401(a) or 403(b) of the Internal Revenue Code, which cover defined contribution, defined benefit, and annuity plans. The form is not for initial submissions but specifically for correcting underpayments after the initial fee has been processed.
Opinion letters are issued by the IRS to confirm that a pre-approved plan’s document complies with tax laws, helping employers adopt plans with confidence in their tax-qualified status. Form 8717-A ensures that the full required fee is paid, preventing delays or rejections in the application process.
You can download the latest version of Form 8717-A (Revised August 2024) directly from the IRS website: https://www.irs.gov/pub/irs-pdf/f8717a.pdf.
Purpose of Form 8717-A and When to Use It
The primary purpose of Form 8717-A is to facilitate additional payments when the initial user fee submitted via Pay.gov for an opinion letter application is insufficient. This applies to applications filed on Forms 4461, 4461-A, 4461-B, or 4461-C, which are used for approval of standardized or nonstandardized pre-approved defined contribution and benefit plans.
Use this form if:
- You’ve already submitted and processed an initial payment through Pay.gov.
- The IRS notifies you of a fee shortfall, or you realize an error in the amount paid.
- You’re applying for opinion letters on pre-approved plans under relevant revenue procedures like Rev. Proc. 2023-37 for § 401(a) plans or Rev. Proc. 2021-37 for § 403(b) plans.
Do not attach Form 8717-A to the initial application forms, as initial fees are now handled exclusively through Pay.gov. This shift emphasizes the form’s role solely in corrections.
Recent Changes to Form 8717-A
As of the August 2024 revision, Form 8717-A has been updated to be used exclusively for additional payments. Previously, it might have been attached to initial applications, but now initial user fees must be paid via Pay.gov. This change streamlines the process and reduces paperwork for standard submissions.
There are no major structural changes noted from previous years in the 2026 guidance, but user fees are updated annually via revenue procedures. The current fees reference Rev. Proc. 2026-4, effective January 1, 2026, which outlines the schedule in Appendix A.
User Fees for Employee Plan Opinion Letters
User fees for opinion letters vary based on the type of submission and plan. These fees are published annually and apply to pre-approved plans under specific revenue procedures. Below is a summary of the key categories from Rev. Proc. 2026-4. Note that Form 8717-A is for paying the difference if the initial amount was short.
| Category | Description | Fee Amount |
|---|---|---|
| Mass or Non-Mass Submitter (Basic Plan with One Adoption Agreement) | Per basic plan document with one adoption agreement under Rev. Proc. 2023-37 for § 401(a) plans | $22,000 |
| Additional Adoption Agreements | Per each additional adoption agreement | $16,500 |
| Single Document Plans | Mass or non-mass submitter single document plan (no adoption agreements) | $35,200 |
| Word-for-Word Adoption | Provider’s word-for-word adoption of mass submitter’s basic plan document per adoption agreement or single document plan (applies to § 401(a) and § 403(b) under various Rev. Procs.) | $300 |
| Minor Modification | Provider’s minor modification of mass submitter’s basic plan document per adoption agreement or single document plan | $1,100 |
| Assumption of Sponsorship | Assumption of sponsorship of a pre-approved plan by a new entity (EIN change), without amendment, per basic plan document or single document plan | $300 |
| Name/Address Change | Change in name and/or address of a provider per basic plan document or single document plan | $0 |
These fees also apply similarly to § 403(b) plans under Rev. Proc. 2021-37 and older procedures like Rev. Proc. 2013-22. If your application falls under multiple categories, calculate the total accordingly. The IRS may return your application if the correct additional fee isn’t paid with Form 8717-A.
For the full schedule and any exemptions (e.g., for certain small plans or entities), refer to Rev. Proc. 2026-4.
How to Complete Form 8717-A?
Filling out Form 8717-A is straightforward but requires accuracy to avoid further delays:
- Provider Information: Enter the name of the plan provider, employer identification number (EIN), plan number, and plan name.
- User Fee Calculation (Line 5): Check the appropriate box(es) for the type of submission (e.g., mass submitter per basic plan, additional adoption agreement). Enter the additional amount due based on the fee schedule in Rev. Proc. 2026-4.
- Payment: Attach a check or money order payable to “United States Treasury” for the additional fee. Do not send cash.
- Signature: The form must be signed by an authorized representative.
Reference the Internal Revenue Code sections for any questions, and check for updates on the IRS website.
Where to Submit Form 8717-A?
Mail Form 8717-A along with your payment to the following addresses:
- U.S. Mail: Internal Revenue Service, Attn: Pre-Approved Plans Coordinator, P.O. Box 2508, Room 6-403, Group 7521, Cincinnati, OH 45201-2508.
- Express Mail or Private Delivery Service: Internal Revenue Service, Attn: Pre-Approved Plans Coordinator, 550 Main Street, Room 6-403, Group 7521, Cincinnati, OH 45202.
Electronic submission is not available for this form, as it’s for physical checks or money orders.
Related Forms and Resources
- Form 4461 Series: For initial applications for pre-approved plans.
- Form 8717: For user fees on determination letters (different from opinion letters).
- Pay.gov: For initial user fee payments.
- IRS Resources: Visit the IRS Retirement Plans page for FAQs, or check opinion letter FAQs.
Final Tips for Compliance
Always double-check fee calculations using the latest revenue procedure to avoid needing Form 8717-A in the first place. If you’re a plan provider in Medan, North Sumatra, or elsewhere, consider consulting a tax professional familiar with U.S. IRS rules for international implications.
This article is for informational purposes only and is not tax advice. For personalized guidance, contact the IRS or a qualified advisor. Stay updated by visiting IRS.gov regularly, as rules can change.