IRS Form 14568-A – IRS Forms, Instructions, Pubs 2026 – In the complex world of retirement plan compliance, staying on top of regulatory requirements is essential for plan sponsors. One key tool for addressing issues is IRS Form 14568-A, which helps correct specific failures in 403(b) plans through the Voluntary Correction Program (VCP). This form, officially titled the Model VCP Compliance Statement – Schedule 1: Plan Document Failures for 403(b) Plans, plays a crucial role in maintaining tax-favored status for these plans. Whether you’re a nonprofit organization, educational institution, or other eligible employer managing a 403(b) plan, understanding this form can help you navigate corrections efficiently.
What Is the Voluntary Correction Program (VCP) and Why Does It Matter?
The VCP is part of the IRS’s Employee Plans Compliance Resolution System (EPCRS), designed to allow plan sponsors to voluntarily fix errors in retirement plans without facing severe penalties or disqualification. For 403(b) plans—tax-advantaged retirement savings vehicles often used by public schools, churches, and tax-exempt organizations—common issues include failing to adopt required plan documents or amendments on time. These “nonamender” failures can jeopardize the plan’s qualified status, leading to tax consequences for both the sponsor and participants.
Form 14568-A specifically addresses plan document failures in 403(b) plans, such as not meeting written plan requirements or missing amendment deadlines under Internal Revenue Code (IRC) Section 403(b). It’s a model document that streamlines VCP submissions, ensuring corrections are documented properly to restore compliance.
Key Updates to Form 14568-A in 2023
Originally focused on interim nonamender failures across various plans, Form 14568-A was redesigned in July 2023 to apply exclusively to 403(b) plan document failures. This revision, reflected in the current version (Rev. 7-2023), provides a structured framework for presenting late amender failures specific to IRC 403(b) plans. The update emphasizes standardized descriptions for common issues, making it easier for applicants to detail failures and corrections. If you’re using an older version (pre-July 2023), the IRS requires resubmission on the updated form for cases received after December 31, 2023.
When Should You Use IRS Form 14568-A?
This form is ideal for correcting “interim nonamender failures” in 403(b) plans, where required amendments were adopted late but before the end of the plan’s remedial amendment period. Examples include:
- Failure to timely adopt a written plan under IRC Section 403(b), Final Treasury Regulations, and Notice 2009-3.
- Missing the initial remedial amendment period ending June 30, 2020, per Revenue Procedures 2017-18, 2019-39, and Notice 2020-35.
- For individually designed plans: Not adopting changes from the Required Amendments List after March 31, 2020, or amendments needed for a favorable determination letter.
It’s not suitable for other types of failures, such as operational errors or discretionary amendments. Use it when the VCP submission involves only these document-related issues, and pair it with Form 14568 (the main Model VCP Compliance Statement) for a complete application.
A major benefit: Upon approval, the IRS treats the corrective amendment as timely adopted, preserving the extended remedial amendment period.
Breaking Down the Sections of Form 14568-A
The two-page form is structured for clarity, requiring the plan name, applicant’s Employer Identification Number (EIN), and plan number on every page. Here’s a section-by-section overview:
Section I: Identification of Failures
This identifies the specific non-compliance issues. Checkboxes cover:
- Written plan requirements for all 403(b) plans.
- Initial remedial amendment period failures.
- For individually designed plans: Required Amendments List items (list each with year and IRS Notice reference), determination letter amendments, or other failures.
Attach additional pages if needed, labeled appropriately.
Section II: Description of Proposed Method of Correction
Detail how the failures were fixed, such as:
- Adopting a retroactive written plan with an enclosed copy.
- Updating the plan document for the initial remedial period, including signed amendments.
- For other failures: Adopting necessary amendments with enclosed documents.
Section III: Change in Administrative Procedures
Explain steps to prevent future failures, like improved review processes or training.
Section IV: Enclosures
List required attachments, such as signed plan documents, amendments, and pre-amendment versions.
How to Complete and Submit Form 14568-A?
To file:
- Use the current July 2023 revision—do not modify the form or add extraneous details.
- Complete it alongside Form 14568 and Form 8950 (VCP Application).
- Include all enclosures, such as signed and dated documents.
- Submit via the IRS’s Pay.gov portal under EPCRS guidelines in Revenue Procedure 2021-30.
- Pay the applicable user fee, which varies by plan size and failure type.
The IRS reviews for completeness; incomplete submissions may require revisions.
Common Mistakes to Avoid with Form 14568-A
From IRS guidance, frequent errors include:
- Not specifying exact tax law items or plan sections affected.
- Listing irrelevant amendments (e.g., those for non-403(b) plans).
- Using the wrong schedule for the failure type—interim amendments go on 14568-A, others on 14568-B.
- Missing enclosures like pre-amendment plan copies or detailed failure descriptions.
Avoid these to speed up approval and prevent rejection.
Where to Download IRS Form 14568-A?
You can download the latest PDF version directly from the IRS website: https://www.irs.gov/pub/irs-pdf/f14568a.pdf. Always check for updates, as forms are revised periodically.
Final Thoughts on Maintaining 403(b) Plan Compliance
IRS Form 14568-A is a valuable resource for rectifying 403(b) plan document failures through the VCP, helping sponsors avoid costly audits or plan disqualifications. By addressing issues proactively, you ensure your retirement plan remains compliant and beneficial for employees. If you’re unsure about applicability, consult a tax professional or review EPCRS resources on IRS.gov. Staying informed on amendment deadlines and using tools like this form can prevent failures before they occur.