IRA providers, like qualified plan sponsors, were required to update their IRA documents for SECURE Act 1.0/2.0 by December 31, 2026, pursuant to IRS Notice 2024-2.  Thankfully, earlier this year IRS issued Notice 2026-9  to extend the deadline for IRAs (traditional, Roth, SEP, SIMPLE) until December 31, 2027.  Importantly, there was no extension for qualified plans (and we understand informally that no extension is forthcoming), and deemed IRAs follow the qualified plan's amendment deadline.

This one-year extension is important as we still do not have updated IRA model forms (last revised in 2017), updated “LRM” (List of Required Modifications) language (generally last updated in 2010), or an open opinion letter program.  Although the rollout of  Trump Accounts, which are based on traditional IRAs, raised expectations that there would be a push to finalize model language, it appears that the extension is necessary after all.   SIMPLE IRA plans (and SIMPLE IRAs) have a number of changes to address, including the new Roth SIMPLE IRAs, so we look forward to the pending guidance.  

In the meantime, providers should indicate on the IRA materials that the documents have not yet been updated for recent law.