If you thought your rollover notice obligations were settled a few years ago, think again. The IRS has released two new model rollover notices—one for Roth distributions and one for non-Roth distributions—and they are effective immediately. That means every plan sponsor who issues distribution paperwork now has one more item on the compliance to-do list.
Sponsors didn’t ask for a new notice, but the law changed. Laws change all the time; plans usually don’t. That gap between updated regulations and everyday operations is where most compliance problems are born. Until your forms and procedures reflect the current requirements, you are relying on yesterday’s rules to run today’s plan.
These revised notices incorporate the many changes made by SECURE 2.0 and other recent legislation. The IRS didn’t simply polish the old language. The new versions address updated early-withdrawal exceptions, revised required minimum distribution rules, and other details that affect how participants experience a distribution. In other words, this isn’t cosmetic—it’s substantive.
The requirement to provide a proper 402(f) safe harbor explanation has never been optional. If a participant is eligible for a rollover, the plan must deliver a notice that is accurate, understandable, and provided at the right time. Sending an outdated form because “that’s what we’ve always used” is not a compliance strategy. It’s a future audit finding waiting to happen.
For some sponsors, this update will be a simple replacement of one document with another. For others, it will reveal bigger questions: Who is responsible for issuing the notices? Are they being sent before the distribution request is processed? Does the recordkeeper know you’re still using old language? Those operational details matter far more than the font size on the form.
This isn’t a technicality. It’s a reminder that retirement plans live in a moving legal world. Updating the rollover notices now is easier than explaining later why you didn’t.
