The IRS has issued the four sample rollover forms SECURE 2.0 ordered in 2022, and the notice states that a plan which uses them gets no safe harbour for doing so

Section 324 of the SECURE 2.0 Act told the Treasury to write sample rollover forms. On Wednesday it produced four of them.

Notice 2026-49 runs to 29 pages and carries an appendix holding a participant's rollover request, a receiving plan's request to the distributing plan, a distributing plan's certification and a receiving plan's acceptance. They cover a rollover between two employer plans, and a rollover between a plan and an individual retirement account in either direction. They do not cover moving one IRA to another.

The design is built around a number. The receiving plan assigns a rollover identification number, and the two plans use that rather than the participant's own identifying details in everything they send each other, with the transfers encrypted. Both sides work from a standard set of data so the same terms mean the same thing at each end. The receiving plan is expected to verify the request and check that the rollover is legitimate before money moves. Electronic transfer is the preferred route throughout.

Where a distributing plan cannot manage an electronic transfer, the notice tells it to write the check to the receiving plan, for the benefit of the participant, and send it to that plan directly.

What using the forms buys a plan

Nothing, for now. The notice states that Treasury and the IRS "are not currently providing safe harbors based on the use of the sample forms and proposed rollover procedures," and that use of both is optional.

"The sample forms will make compliance simpler and easier for both plan participants and administrators," Frank J. Bisignano, the IRS Chief Executive Officer, said in the announcement.

The part that is not in the forms

Section IV of the notice lists four pieces of guidance under consideration, and they are the reason to read past the appendix.

The first would strike Q&A-4 out of the regulations under section 1.401(a)(31)-1, which is the provision that lets a plan complete a direct rollover by mailing a paper check to the participant, and would remove the safe harbor in Situation 2 of Revenue Ruling 2014-9. The second would require rollovers to travel electronically, or by a check sent straight to the receiving plan. The third would build safe harbors on top of the sample forms, so that a receiving administrator using them could conclude the distributing plan is qualified and the contribution is valid, absent evidence otherwise. The fourth would declare more practices impermissible, and names one: requiring a Medallion Signature Guarantee.

The notice cites Executive Order 14247 for the proposition that federal checks are over 16 times more likely to be lost, stolen, altered or delayed than electronic payments.

Comments are due by October 23, referencing Notice 2026-49, under docket IRS-2026-0100. The principal author is Gregory Burns of the Office of Associate Chief Counsel for Employee Benefits, Exempt Organizations, and Employment Taxes.