IRS Form 15417-I – IRS Form, Instructions, Pubs 2026

IRS Form 15417-I – If your organization sponsors or administers a 403(b) retirement plan that uses a retirement income account (often called a 403(b)(9) plan), IRS Form 15417-I is a critical compliance tool. This worksheet, officially titled 403(b) Plan – 403(b)(9) Retirement Income Accounts Worksheet 16 – Determination of 403(b) Status, helps verify that the plan meets all requirements to qualify as a tax-advantaged 403(b) arrangement.

The form (revised April 2023) is part of the IRS’s suite of 403(b) review worksheets used in the pre-approved plan program and for self-compliance checks. It must be completed first if the plan is structured as a 403(b)(9) retirement income account. A “Yes” answer on most items supports favorable 403(b) status; a “No” signals a potential problem that must be explained and corrected.

What Is a 403(b)(9) Retirement Income Account?

Under IRC Section 403(b)(9), a retirement income account is a defined contribution program established or maintained by a church (or convention/association of churches) for its employees (including ministers and certain church-related organizations). It is treated as an annuity contract for 403(b) purposes, even when invested in mutual funds rather than traditional annuities.

Key advantages of 403(b)(9) accounts include:

  • Availability to churches, qualified church-controlled organizations (QCCOs), non-qualified church-controlled organizations (non-QCCOs) in certain cases, and self-employed ministers.
  • Special flexibility for commingling assets and group trusts.
  • For ordained ministers: potential exclusion of designated housing allowances from gross income at distribution (subject to rules in Pub. 517).
  • Exemption from many ERISA requirements for qualifying church plans.

Only church-related organizations (as defined in Treas. Reg. § 1.403(b)-2(b)(6)) may sponsor these accounts. Regular 501(c)(3) organizations generally use annuity contracts or custodial accounts instead.

Who Needs Form 15417-I?

Use this worksheet if:

  • Your plan document designates any portion as a retirement income account under § 403(b)(9).
  • You are a church, convention/association of churches, church retirement board, QCCO, non-QCCO, or self-employed minister establishing a 403(b) plan.
  • You are submitting a plan for IRS opinion/advisory letter under the 403(b) pre-approved plan program.
  • You are performing a self-audit or third-party review of plan document compliance.

Note: Even if the account invests only in mutual funds, it must still satisfy the stricter distribution and annuity-like rules that apply to 403(b) annuity contracts.

Structure of Worksheet 16 (Form 15417-I)

The form is divided into seven main sections. All items must be answered Yes, No, or N/A, with plan document references and explanations for any “No” answers.

I. Applicability

  • Is the account a defined contribution program?
  • Does the plan explicitly state it is intended to be a § 403(b)(9) retirement income account?

II. Employer & Employee Eligibility

  • Is the sponsor a qualifying church-related organization (church, convention, school, church board, QCCO, or self-employed minister)?
  • Is participation limited to employees (and beneficiaries) of church-related organizations?

III. Core Requirements for a 403(b)(9) Account

  • Separate accounting for the account’s interest in underlying assets.
  • Investment performance based solely on gains/losses of those assets.
  • Assets used exclusively for participants/beneficiaries.
  • Loans or extensions of credit from the account to the employer are treated as a diversion of assets.

IV. Funding Vehicles (Special Church Rules)

  • Commingling in a common fund — Allowed only with amounts devoted exclusively to church purposes.
  • Group trusts — May only include assets from retirement income accounts, custodial accounts, 401(a) qualified plans, or IRAs (§ 408).

V. Nondiscrimination

  • If only elective deferrals are provided, this section may be skipped.
  • For non-church or non-QCCO employers making other contributions: the plan must include proper nondiscrimination language (cross-references Worksheets 1A, 11A, 5B, and 6A).

VI. Contribution Limits

  • Cross-reference Worksheet 6A (including special “denominational service” rules for ministers).

VII. Distributions

  • Life annuity benefits must satisfy present-value and guarantee rules under Treas. Reg. § 1.403(b)-9(a)(5).
  • Distributions must follow annuity contract rules (even if invested in mutual funds) — see Worksheet 15.
  • Ownership or use of any account asset by a participant is treated as a distribution.

How to Complete and Use the Worksheet?

  1. Download the current form → IRS Form 15417-I (PDF) (April 2023 revision).
  2. Have the full plan document and adoption agreement ready.
  3. Answer every line and cite the specific plan section.
  4. Explain every “No” answer in detail — this is required for IRS review.
  5. If the plan fails any critical requirement, amend the document before submission or operation.
  6. Retain the completed worksheet with your plan records.

Pro tip: Because Worksheet 16 must be used first for any 403(b)(9) account, complete it before Worksheets 1A (Eligibility), 5B (Nondiscrimination – Employer Contributions), 6A (Limits), 11A (Matching/After-Tax), and 15 (Distributions).

Related IRS 403(b) Worksheets (Series 15417)

The IRS provides a full set of interconnected worksheets (revised April 2023) for comprehensive 403(b) document review:

  • Worksheet 1A → Eligibility and Participation
  • Worksheet 5B → Nondiscrimination – Employer Contributions
  • Worksheet 6A → Contribution Limits
  • Worksheet 11A → Matching & After-Tax Contributions
  • Worksheet 15 → Distributions
  • Worksheet 16 (15417-I) → 403(b)(9) Retirement Income Accounts (this one)

All are available on IRS.gov under Forms & Instructions.

Why Compliance Matters?

Failing to satisfy § 403(b)(9) requirements can cause the entire arrangement to lose its tax-deferred status. Contributions may become immediately taxable, and the plan could face disqualification. Using Form 15417-I as part of a documented review process gives plan sponsors, administrators, and advisors confidence that the retirement income account meets current IRS standards.

Recent note: The April 2023 revision aligns with the 2021 Required Amendments List and incorporates updates from SECURE Act provisions affecting church-controlled organizations.

Download & Official Resources

  • Direct PDF: Form 15417-I
  • Full list of 403(b) worksheets and pre-approved plan information: IRS.gov → Retirement Plans → 403(b) Pre-Approved Plans
  • Background on 403(b) plans: IRC 403(b) Tax-Sheltered Annuity Plans
  • Publication 571: Tax-Sheltered Annuity Plans (403(b) Plans)
  • Publication 4546: 403(b) Plan Checklist

Final Thoughts

IRS Form 15417-I (Worksheet 16) is the gateway document for any church or church-related organization that wants to offer a 403(b)(9) retirement income account. By systematically addressing applicability, eligibility, exclusive benefit rules, funding vehicles, nondiscrimination (where required), limits, and distributions, sponsors can ensure their plan qualifies for the significant tax advantages of a 403(b) arrangement.

Whether you are drafting a new plan, updating an existing one for the latest remedial amendment period, or preparing for an IRS opinion letter, start with Form 15417-I. Proper use of this worksheet, combined with the rest of the 15417 series, provides a clear roadmap to 403(b) compliance.

Need help? Consult a qualified retirement plan attorney, TPA, or IRS-approved pre-approved plan sponsor. Always verify the latest form and instructions on IRS.gov, as technical principles may change with future guidance.

Last updated: February 2026 – based on the April 2023 revision of Form 15417-I and current IRS publications.