The IRS issued its annual Required Amendment List ("RAL"), Notice 2025-60, that provides the deadline for certain law changes that impact individually-designed and pre-approved qualified plans. The 2025 RAL has two items that made the list, which will require plan amendments by December 31, 2027: 

(1) Required Minimum Distributions (Code section 401(a)(9)). Changes set forth in Sections 114 and 401 of the SECURE 1.0 Act, and the final 2024 Regulations (these changes impact the participant's required beginning date, and the required distributions to beneficiaries) made the list. (The 2024 proposed regulations are not yet on a RAL.) 

(2) Partnership and Trust Attribution Rules (89 Fed. Reg. 106848). This final regulation extends the partnership and trust attribution rules to the determination of whether a parent-subsidiary controlled group exists under section 414(c) of the Code (trades or businesses under common control). The change applies to plan years beginning on or after January 1, 2025.

Notably, the final Roth catch-up regulations did not make the list as they are not effective until January 1, 2027. The Notice indicates that they (and Section 603 of SECURE 2.0 changes) should make the 2027 RAL, giving plan sponsors plenty of time to finalize the plan amendment.