What NFPs Need to Know About the 403(b) Plan Cycle 2 Restatement

If your not-for-profit organization sponsors a 403(b) retirement plan, now is the time to take action. The IRS has officially opened the Cycle 2 403(b) Pre-Approved Plan Restatement window, and plan sponsors have until December 31, 2026 to complete the required restatement to maintain their plan’s tax-qualified status (IRS Announcement 2024-38).

At Clark Schaefer Hackett (CSH), we understand that retirement plan compliance can be complex—especially for not-for-profit leaders who already wear many hats. That’s why our Qualified Plan Administration and Consulting (QPAC) team is here to guide you through the restatement process with clarity and confidence.

The IRS requires periodic restatements of pre-approved retirement plan documents to ensure that plans comply with current laws and regulations. This is the second mandated 6-year restatement cycle for 403(b) plans, commonly referred to as “Cycle 2.”

If your organization uses a pre-approved plan document (as most not-for-profits do), you must update your plan document to reflect recent legislative and regulatory changes. Failing to complete the restatement by the 2026 deadline could jeopardize your plan’s tax-favored status.

Not-for-profits often rely on 403(b) plans to attract and retain talent while aligning with their mission-driven goals. But because many NFPs operate with lean administrative staff, key compliance deadlines like this one can slip under the radar. That’s where a proactive approach becomes essential.

At CSH, we’ve helped countless not-for-profit organizations manage their 403(b) plan responsibilities. Our QPAC team uses Relius Documents, an industry-standard system for pre-approved plans, to ensure accuracy and compliance at every step.

If your plan was originally set up using a pre-approved document, you will need to:

Whether you need a full document restatement, a compliance check, or assistance communicating with your board or plan participants, our QPAC specialists are ready to help. We’re already preparing restatement packages for clients and can easily assist those who haven’t yet engaged a document provider.

Now is the time to assess your plan status and plan ahead. Don’t wait until 2026 approaches—getting a head start will ensure compliance and peace of mind.

If you’d like to learn more about how CSH can support your organization’s retirement plan needs, or if you'd like help communicating this restatement requirement to your team or board, contact our QPAC team today.