IRS Form 15417-D – Tax-exempt organizations, schools, hospitals, and churches sponsoring 403(b) plans must ensure strict compliance with IRS contribution limits to maintain the plan’s tax-advantaged status. IRS Form 15417-D (Worksheet 6A – Determination of 403(b) Status) serves as a critical compliance tool for reviewing plan documents regarding limitations on contributions and benefits.
This article explains what Form 15417-D is, who needs it, how to use it, key requirements under IRC Sections 415, 402(g), and 401(a)(17), current 2026 limits, and best practices for 403(b) plan sponsors and administrators.
What Is IRS Form 15417-D?
Form 15417-D (revised April 2023) is titled “403(b) Plan – Plan Limitation on Contribution and Benefits Worksheet 6A – Determination of 403(b) Status.” It functions as a checklist-style worksheet that helps reviewers determine whether a 403(b) plan document properly incorporates federal tax law requirements for contribution and benefit limitations.
A “Yes” answer on the worksheet generally indicates compliance, while a “No” signals a potential defect that requires explanation or correction. Plan sponsors and tax professionals use it during self-reviews, remedial amendments, or IRS determination letter applications for individually designed 403(b) plans.
Note: Dollar amounts in the 2023 form (e.g., $61,000 annual additions limit and $305,000 compensation limit for 2022) are examples only. Limits adjust annually for inflation.
Why Contribution Limits Matter in 403(b) Plans?
403(b) plans (tax-sheltered annuities or custodial accounts) allow employees of eligible employers to save for retirement with tax-deferred (or Roth) growth. Exceeding limits can result in:
- Excise taxes on excess contributions
- Plan disqualification
- Loss of tax benefits for participants and the sponsor
Worksheet 6A focuses on:
- Section 402(g) — Limits on elective deferrals
- Section 415(c) — Limits on annual additions
- Proper definitions of compensation, limitation year, and years of service
- Special catch-up provisions and aggregation rules
Who Should Use Form 15417-D?
- Sponsors of individually designed 403(b) plans applying for an IRS determination letter (initial qualification or termination)
- Plan administrators and third-party administrators conducting compliance reviews
- ERISA counsel and tax advisors updating or restating plan documents
- Organizations with church plans, public schools, or qualified organizations eligible for special 15-year catch-up rules
Pre-approved 403(b) plans generally do not require this level of individual review, but individually designed plans do, especially under the expanded IRS determination letter program that began accepting applications in 2023.
Step-by-Step Guide to Worksheet 6A
The worksheet is divided into four main sections. All items must be addressed unless the plan document clearly makes them inapplicable.
I. Definitions
Reviewers must verify that the plan document includes accurate definitions:
- Limitation year — Must follow Treas. Reg. §1.415(j)-1 (typically the calendar year or plan year).
- Includible compensation — Defined under §1.403(b)-2(b)(11) and used for §415 limits. Special rules apply for self-employed ministers, post-severance compensation, differential wage payments, and difficulty of care payments. Former employees are deemed to have includible compensation for up to five years after severance.
- Year of service — For includible compensation, special 403(b) catch-up, and former employee contributions: full-time for the entire work period plus pro-rata for part-time.
- Church employee aggregation — Church plans must aggregate service across associated church-related organizations.
II. Limits on Elective Deferrals (Section 402(g))
Skip if the plan has no elective deferrals.
- Elective deferrals must not exceed the annual §402(g) limit (aggregated across all 403(b) and other eligible plans of the employer).
- The plan must permit (or properly exclude) age 50 catch-up contributions.
- For qualified organizations (e.g., certain educational, hospital, or church entities), the plan may allow the special 15-year service catch-up (up to $3,000 per year, lifetime limit $15,000), with proper definitions of qualified employee and aggregation of service and prior catch-ups across controlled church-related organizations.
- If both age 50 and 15-year catch-ups are available, excess deferrals are allocated first to the 15-year catch-up, then to age 50.
III. Limitations on Annual Additions (Section 415(c))
- Annual additions (elective deferrals + employer contributions + forfeitures) cannot exceed the lesser of:
- The §415(c) dollar limit (adjusted annually), or
- 100% of the participant’s includible compensation for the limitation year.
- Excess annual additions must be placed in a separate “excess” account that is not treated as a 403(b) contract until distributed.
- Special rules for contributions to former employees and permanently/totally disabled participants (nonforfeitable, nondiscriminatory).
- All 403(b) contracts for a participant are aggregated as one contract.
- Controlled employer aggregation applies if the participant controls another employer.
IV. 401(a)(17) Limitation on Compensation
The plan must cap compensation considered for contributions at the §401(a)(17) limit (does not apply to elective deferrals or to churches/qualified church-controlled organizations).
Current 403(b) Contribution Limits (2026)
Limits adjust annually. As of 2026:
- Elective deferral limit (§402(g)): $24,500
- Age 50+ catch-up: $8,000 (total $32,500)
- Special catch-up for ages 60–63 (SECURE 2.0): $11,250 in applicable years
- Annual additions limit (§415(c)): $72,000 (or 100% of includible compensation, whichever is less)
- 401(a)(17) compensation limit: $360,000 (general); higher for certain grandfathered governmental plans
Always verify the latest limits on IRS.gov, as they are subject to cost-of-living adjustments.
Common Pitfalls and How to Fix “No” Answers
- Missing or incorrect definitions of includible compensation or limitation year
- Failure to aggregate plans for §402(g) or §415 limits
- Improper handling of excess contributions (must go to a non-403(b) account)
- Omitting special church or qualified organization rules
- Applying the 401(a)(17) limit where it is not required
Document explanations for any “No” and amend the plan document as needed during the remedial amendment period.
How to Download and Use Form 15417-D?
Download the official PDF directly from the IRS: https://www.irs.gov/pub/irs-pdf/f15417d.pdf.
Use it alongside other 403(b) worksheets (e.g., eligibility, distributions, miscellaneous provisions) for a comprehensive compliance review.
Frequently Asked Questions (FAQs)
Is Form 15417-D filed with the IRS?
No. It is a worksheet for internal or determination letter review, not a tax return form.
Do pre-approved 403(b) plans need this worksheet?
Generally no, but sponsors of individually designed plans do, especially when seeking a favorable determination letter.
Are the limits in the form current?
No—the form uses 2022 examples. Always use the latest IRS cost-of-living adjustment (COLA) notices.
What if my plan has excess contributions?
Excess annual additions must be segregated into a non-403(b) account. Elective deferral excesses are handled under §402(g) correction rules.
Ensure Your 403(b) Plan Remains Compliant
IRS Form 15417-D provides an essential roadmap for verifying that your 403(b) plan document correctly limits contributions and benefits. Proper use helps avoid costly penalties and supports a favorable IRS determination letter when needed.
Plan sponsors should work with qualified retirement plan counsel or administrators familiar with 403(b) rules. For the most current guidance, visit IRS.gov/retirement-plans and review the latest COLA announcements and Revenue Procedures.
Download the form today and incorporate Worksheet 6A into your next plan review to maintain the tax-favored status of your 403(b) retirement plan.
This article is for informational purposes only and is not tax or legal advice. Consult a qualified professional for your specific situation.