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Official form guide
Form 14568: Model VCP Compliance Statement
Treasury - Internal Revenue Service Form 14568 is a Model VCP Compliance Statement used to notify the IRS of failures in plan compliance. The form must include the plan name, Applicant’s EIN, and plan number on each page.
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IRS Form 14568 - Model VCP Compliance Statement
Treasury - Internal Revenue Service Form 14568 is a Model VCP Compliance Statement used to notify the IRS of failures in plan compliance. The form must include the plan name, Applicant’s EIN, and plan number on each page.
Risk Radar
Scan points- 1Failing to include the plan name, Applicant’s EIN, and plan number on every page of Form 14568 is a critical error.
- 2Omitting plan name/EIN/plan number on attachments for Section II failures.
- 3Failing to specify which Schedules are included if using Form 14568 Schedules.
- 4Not attaching the supporting rationale when requesting relief from specific IRC Excise Taxes in Section VI.
- 5Requesting different loan reliefs inconsistently across all loans submitted.
Plain English
This form tells the IRS that your retirement or benefit plan has had certain compliance issues (failures). By filing Form 14568, you are asking the IRS to grant specific relief regarding those failures, such as how distributions are reported or whether excise taxes must be paid. You also confirm what tax rules apply to these corrected loans.
Submission Date
- Filing date: 2023-08-01 22:11:56
- Preparation window: collect IDs, supporting records, and signatures in advance.
- Final review: verify names, dates, and required fields before submission.
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What this form is for
- Use this form when an entity needs to notify the IRS of failures in plan compliance regarding a Model VCP (Voluntary Compliance Program).
- Do not use Form 14568 when submitting a general tax return without detailing specific compliance failures.
- Check Form 1099-R instead when reporting deemed distributions related to loan corrections.
Form selector
Use this form or another form?
Loan failure correction
Used to request relief regarding how deemed distributions are reported for plan loans not complying with IRC Section 72(p).
✓ Check the specific request types on Page 2.
General compliance statement
This form serves as the primary document to state overall VCP compliance status.
✓ Ensure all required sections (I, II, III, V, VI) are addressed.
Remedial amendment cycle
Used when a corrective amendment might cause the plan to lose its pre-approved status under IRC Section 401(a) or 403(b).
✓ Confirm the employer remains within the six-year remedial amendment cycle.
Deadline or filing window
The filing relates to corrective amendments for failures described in the compliance statement. The form confirms that if certain conditions are met regarding loan corrections, the employer will remain within the six-year remedial amendment cycle described in Rev. Proc. 2016-37 (and future guidance).
Checklist
What you need before filling it out
Plan Name
The name of the plan · Section I (p.1) / Header (p.2, p.3)
Applicant’s EIN
The entity's Employer Identification Number (do not use SSN) · Section I (p.1) / Header (p.2, p.3)
Plan Number
The specific identifier for the plan · Section I (p.1) / Header (p.2, p.3)
Excise Tax Requests
Specific IRC section numbers requested relief for (e.g., 4972, 4973) · Section VI (p.1)
Deemed Distribution Reporting
Request to report deemed distributions in year of correction instead of failure year · Page 2
Before you submit
- 1Confirm the plan name, Applicant’s EIN, and plan number are listed on every page of Form 14568 (Rev. 7-2023) and its attachments.
- 2If attaching Schedules, specify which Schedules are included on Form 14568.
- 3Ensure the attachment labeled “Section II. Applicant’s Description of Failures” lists and numbers each failure separately.
- 4Verify that the attachment for Section II includes the plan name, Applicant’s EIN, and plan number on every page.
- 5Check that the attachment labeled “Section III. Applicant’s Description of the Proposed Method of Correction” describes the correction method for each failure listed in Section II.
- 6Confirm that the attachment for Section III includes the plan name, Applicant’s EIN, and plan number on every page.
- 7Verify that the attachment labeled “Section IV. Applicant’s Proposed Procedures to Locate and Notify Former Employees or Beneficiaries” describes the notification methods or provides an affirmative statement.
- 8Ensure the attachment for Section V (if used) includes an explanation of how and why the failures arose, along with the corrective measures.
How to file this form
- 1Complete all required fields on Form 14568, including identifying information in Section I and detailed descriptions/proposals across Sections II through V.
- 2Attach necessary supporting documents, labeling them correctly (e.g., “Section III. Applicant’s Description of the Proposed Method of Correction”), ensuring each attachment also bears the plan name, EIN, and plan number.
- 3Review the specific relief requests on Page 2 to ensure they align with all loan failures described in Section II, particularly regarding Form 1099-R reporting.
- 4Sign and date Form 14568 (and any attachments) before mailing it to the IRS for processing.
Known limitations
- 1The submission of Form 14568 does not constitute a determination as to whether the written plan complies with the requirements associated with IRC Section 403(b) and the Final Treasury Regulations under IRC Section 403(b).
- 2If relief is not applied consistently to all loans, this compliance statement does not guarantee that the corrective amendment will prevent the plan from losing its status as a pre-approved IRC Section 401(a) or pre-approved IRC Section 403(b) plan.
- 3The employer may lose reliance on the plan’s opinion or advisory letter if a modification is made to either the plan document or adoption agreement of the plan, which affects failure number relief.
- 4If a modification is made that would affect the employer’s eligibility for the six-year remedial amendment cycle, this compliance statement does not guarantee the employer will remain within that cycle described in Rev. Proc. 2013-22 and Rev. Proc. 2016-37.
Field map
Compact field-by-field guide
General Info
2 items
Full legal name and taxpayer identification number (SSN or EIN).
Current mailing address.
Details
2 items
Complete all applicable sections of this form according to the official IRS instructions.
Enter the relevant dollar amount if this form involves tax calculation.
Certification
1 items
Read and acknowledge any certifications required by this form.
Signatures
1 items
Sign and date. Unsigned forms cannot be processed.
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Fillable formOpen in Editor->The current edition of IRS Form 14568 is Revision 7-2023, dated July 2023; the source directs users to check the current EPCRS Revenue Procedure for Paperwork Reduction Act information.
What changed or needs a fresh check
- Edition date — confirm the revision date reads July 2023.
- Catalog Number — confirm the number is 66138J.
- IRS Website — confirm the URL listed is www.irs.gov.
- Signature — ensure the form includes a space for the Manager's signature and the Date of approval.
Quick Facts
Downloads
After you file
- 1Retain a copy of Form 14568 (Rev. 7-2023) for record-keeping.
- 2If using schedules, ensure the attached copies specify which Schedules are included on Form 14568.
- 3Ensure that if relief is requested only for some loans, all repayments made pursuant to the correction will not result in additional basis unless specified otherwise.
- 4For loans where relief from issuing Form 1099-R is applicable, retain documentation showing that repayments did not create additional participant basis.
Sources
- SRCInstructions p.1 — The plan name, Applicant’s EIN, and plan number must be included on each page of the compliance statement.
- SRCInstructions p.1 — Section I requires listing the Applicant’s name, Applicant’s EIN (must not use SSN), Plan number, and Plan name.
- SRCInstructions p.1 — If using Form 14568 Schedules, the filer must specify the included Schedules and attach them to this compliance statement.
- SRCInstructions p.2 — The applicant requests that a deemed distribution corrected via VCP is not required to be reported on Form 1099-R.
- SRCInstructions p.3 — Relief may allow reporting deemed distributions on Form 1099-R in the year of correction instead of the year of failure, even if relief isn't applied consistently.
- SRCInstructions p.2/p.3 — The compliance statement does not constitute a determination as to whether the written plan complies with IRC Section 403(b) requirements.
Common confusion points
What must be included on every page of the compliance statement?
The plan name, Applicant’s EIN, and plan number must appear on each page of Form 14568 and all its attachments.
→ Verify these three items are present on Page 1 through Page 3.
When should you use an attachment for Section II?
Use an attachment if the failures cannot fit entirely on the main form, labeling it “Section II. Applicant’s Description of Failures.”
→ Check that this attachment includes the plan name, EIN, and plan number on every page.
What is the key difference between Section III and Section IV attachments?
Section III describes *how* to fix the failure; Section IV describes *who* will be contacted about the failure.
→ Confirm the labels match: “Section III...” vs. “Section IV...”.
Does this form guarantee compliance?
No, Form 14568 does not constitute a determination that the written plan complies with IRC Section 403(b) and Final Treasury Regulations under IRC Section 403(b).
→ Look for the disclaimer on Page 2 to confirm this limitation.
If relief is not applied consistently, what happens?
If the requested relief isn't consistent across all loans, the IRS will require deemed distributions under IRC Section 72(p) to be reported on Form 1099-R for affected participants.
→ Check Page 3 for this specific condition.
Does using Form 14568 automatically mean you are within the six-year remedial amendment cycle?
Not necessarily; the corrective amendment will not cause the plan to lose its status as a pre-approved IRC Section 401(a) or pre-approved IRC Section 403(b) plan, provided certain conditions are met.
→ Review Page 3 for the dependency clauses regarding this allowance.
Workflow map
Related forms and next steps
Before
Current
After
Often used with
⚠ If something goes wrong
- If requested relief is not applied consistently to all loans, the default reporting rules for Form 1099-R apply.
Questions about IRS Form 14568
What is IRS Form 14568 used for?
This form tells the IRS that your retirement or benefit plan has had certain compliance issues (failures). By filing Form 14568, you are asking the IRS to grant specific relief regarding those failures, such as how distributions are reported or whether excise taxes must be paid. You also confirm what tax rules apply to these corrected loans.
Who must file IRS Form 14568?
The Applicant, which is the entity submitting the form, files Form 14568 with the Internal Revenue Service (IRS).
What information does IRS Form 14568 require?
Section I collects identifying information like the plan name, Applicant’s EIN, and plan number. Section II lists and numbers each failure, and Sections VI and VII detail specific tax requests.
Where do I file IRS Form 14568?
The form must include the plan name, Applicant’s EIN, and plan number on every page, including attachments. The current edition is Form 14568 (Rev. 7-2023), Catalog Number 66138J.
How do I complete IRS Form 14568?
First, complete Section I with all identifying data. Next, detail failures in Section II, ensuring each attachment is labeled correctly. Finally, specify requests in Sections VI (Excise Taxes) and VII (Enforcement Resolution), then sign before sending.
What happens if IRS Form 14568 is filed incorrectly?
If relief is not applied consistently to all loans, the IRS may require deemed distributions under IRC Section 72(p) to be reported on Form 1099-R for affected participants. The plan sponsor also agrees that the IRS will not pursue revocation of the tax-favored status.
What must be included on every page of the compliance statement?
The plan name, Applicant’s EIN, and plan number must appear on each page of Form 14568 and all its attachments. Verify these three items are present on Page 1 through Page 3.
When should you use an attachment for Section II?
Use an attachment if the failures cannot fit entirely on the main form, labeling it “Section II. Applicant’s Description of Failures.” Check that this attachment includes the plan name, EIN, and plan number on every page.
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