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Form 14568B: Model VCP Compliance Statement - Schedule 2: Nonamender Failures for IRC 401(a) Plans
Internal Revenue Service Form 14568-B is a Model VCP Compliance Statement (Schedule 2) that plan sponsors of IRC 401(a) plans use to report non‑amender failures, such as missing the April 30, 2010 deadline for adopting a pre‑approved defined‑contribution plan.
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IRS Form 14568B - Model VCP Compliance Statement - Schedule 2: Nonamender Failures for IRC 401(a) Plans
Internal Revenue Service Form 14568-B is a Model VCP Compliance Statement (Schedule 2) that plan sponsors of IRC 401(a) plans use to report non‑amender failures, such as missing the April 30, 2010 deadline for adopting a pre‑approved defined‑contribution plan.
Risk Radar
Scan points- 1Omitting the plan name, EIN, or plan number from any page leads to rejection.
- 2Failing to list the plan name, Applicant’s EIN, or plan number on every page of the statement.
- 3Not checking the specific pre‑approved plan deadline that applies (e.g., April 30, 2010) in Section I.
- 4Leaving Section I.B. blank for individually designed plans when a 5‑year remedial cycle applies.
- 5Omitting the required attachment label “Section I.C. of Form 14568‑B, Identification of Other Nonamender Failures.”
Plain English
This form tells the IRS which required amendments a 401(a) retirement plan missed and how the sponsor will fix them. It also requires the sponsor to attach the corrected plan documents and describe steps to prevent future failures.
Submission Date
- Filing date: 2023-08-01 22:11:58
- 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 a plan sponsor of an IRC 401(a) plan needs to report non‑amender failures (e.g., missed adoption deadlines for pre‑approved or individually designed plans).
- Do not use it when the plan has already been amended to cure the failure or when reporting compliance issues not covered in Section I of the form.
Form selector
Use this form or another form?
Missed pre‑approved plan adoption deadline
Required to report non‑amender failure for pre‑approved plans
✓ Verify the plan name, EIN, and plan number are on the page
Individually designed plan not amended within 5‑year cycle
Used to list failures from the Cumulative List or Required Amendments List
✓ Confirm the correct Cumulative List year is cited
Other non‑amender failure not listed in Section I
Schedule 2 captures any other IRC 401(a) failures
✓ Ensure attachment labeled “Section I.C…” is included
Deadline or filing window
Not stated in the official source.
Checklist
What you need before filling it out
Plan name
Plan name as on plan document · Section I header
Applicant’s EIN
Employer Identification Number · Section I header
Plan number
Assigned plan number · Section I header
Section I – Identification of Failures
List of missed adoption deadlines with Cumulative List year and notice reference · Section I of Form 14568-B
Section II – Description of Proposed Method of Correction
Narrative describing adopted amendments · Section II of Form 14568-B
Before you submit
- 1Enter the plan name on the top of each page
- 2Enter the Applicant’s EIN on the top of each page
- 3Enter the plan number on the top of each page
- 4Check each applicable failure box in Section I
- 5Attach a labeled page for Section I.B if using the Cumulative List
- 6Attach a labeled page for Section I.C if reporting other failures
- 7Include copies of signed and dated amendments as required in Section IV
- 8Sign and date the form in the designated signature area
How to file this form
- 1Complete all identification fields (plan name, EIN, plan number) on each page
- 2Mark every applicable failure in Section I and provide required details
- 3Prepare and attach labeled pages for Section I.B or I.C as needed
- 4Enclose copies of signed amendments and prior plan document per Section IV
- 5Sign and date the form
- 6Mail the completed Form 14568-B to the IRS address indicated in the instructions and retain a copy for records
Known limitations
- 1The form does not apply to retirement plans that are not classified as IRC 401(a) plans.
- 2Individually designed plans that were not subject to the 5‑year remedial amendment cycle before January 1 2017 are excluded from the Cumulative List requirement.
- 3Pre‑approved plan failures are limited to the specific adoption deadlines listed for the 2004, 2006, 2010, 2012, and 2017 Cumulative Lists.
- 4The “Other” category must be used for any late‑amender failure not enumerated in sections A or B, and must be attached as a separate labeled page.
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->Form 14568-B is currently issued as Revision July 2023 (Rev. 7‑2023). The source is the form itself, which serves as the latest official version.
What changed or needs a fresh check
- Edition date — confirm the form shows Rev. 7‑2023
- Fee — Not stated in the official source
- Mailing address — Not stated in the official source
- Signature — confirm the form is signed and dated by the applicant
Quick Facts
Downloads
After you file
- 1Retain copies of the signed and dated amendments submitted with the VCP filing.
- 2Keep a copy of the plan document that was in effect before the amendments.
- 3File the most recent determination letter with the submission, if applicable, and retain it for records.
- 4Ensure each attached page includes the plan name, Applicant’s EIN, and plan number at the top.
Sources
- SRCForm p.1 — title and revision: Form 14568‑B (Rev. 7‑2023) Model VCP Compliance StatementSchedule 2: Nonamender Failures for IRC 401(a) Plans.
- SRCForm p.1 — requirement to include plan name, Applicant’s EIN, and plan number on each page.
- SRCForm p.1 — pre‑approved plan deadline April 30 2010 for 2004 Cumulative List (Notice 2004‑84) as required by Announcement 2008‑23.
- SRCForm p.1 — pre‑approved plan deadline April 30 2012 for 2006 Cumulative List (Notice 2007‑3) as required by Announcement 2010‑20.
- SRCForm p.1 — pre‑approved plan deadline April 30 2016 for 2010 Cumulative List (Notice 2010‑90) as required by Announcement 2014‑16.
- SRCForm p.1 — pre‑approved plan deadline July 31 2020 for 2012 Cumulative List (Notice 2012‑76) as required by Notice 2018‑5 and Notice 2020‑35.
- SRCForm p.1 — pre‑approved plan deadline July 31 2022 for 2017 Cumulative List (Notice 2017‑37) as required by Announcement 2020‑7.
- SRCForm p.1 — individually designed plans subject to 5‑year remedial amendment cycle prior to Jan 1 2017 are covered by the Cumulative List.
- SRCForm p.2 — Section IV enclosures list: copies of signed and dated amendments, copy of prior plan document, copy of most recent determination letter (if applicable).
- SRCForm p.2 — Section I.C requires “Other” category for failures not listed above and attachment labeling.
Common confusion points
Do I need to list every missed deadline for pre‑approved plans?
The form lists multiple Cumulative List deadlines, so filers may be unsure which apply.
→ Verify that the plan’s missed adoption date matches one of the listed deadlines (e.g., April 30 2010, April 30 2012, April 30 2016, July 31 2020, July 31 2022).
Can I use Form 14568‑B for a retirement plan that isn’t an IRC 401(a) plan?
The title and purpose specify IRC 401(a) plans only.
→ Confirm the plan is classified as an IRC 401(a) plan before filing.
Are individually designed plans that weren’t under the 5‑year remedial cycle before 1 Jan 2017 required to report here?
Section B limits coverage to those subject to the 5‑year cycle prior to that date.
→ Check the plan’s amendment cycle start date; if after 1 Jan 2017, this form does not apply.
Where should I attach additional pages for Section I.B.?
The source requires specific labeling of attachments.
→ Label each attachment “Section I.B. of Form 14568‑B, Identification of Failures, The Changes required by the Cumulative List” and include plan name, EIN, and plan number at the top.
Do I have to put the plan name, EIN, and plan number on every page of the submission?
The form explicitly instructs inclusion on each page.
→ Ensure each page and attachment displays the plan name, Applicant’s EIN, and plan number.
What if my failure isn’t listed in sections A or B?
Section C provides an “Other” option for unlisted failures.
→ Use the “Other (specify the late amender failure not listed above)” field and attach a page labeled “Section I.C.of Form 14568‑B, Identification of Other Nonamender Failures.”
Workflow map
Related forms and next steps
Before
Current
After
Often used with
⚠ If something goes wrong
- Form 8857 – Request for a private letter ruling, used when clarification of VCP requirements is needed.
Questions about IRS Form 14568B
What is IRS Form 14568B used for?
This form tells the IRS which required amendments a 401(a) retirement plan missed and how the sponsor will fix them. It also requires the sponsor to attach the corrected plan documents and describe steps to prevent future failures.
Who must file IRS Form 14568B?
Plan sponsors of IRC 401(a) retirement plans must file IRS Form 14568‑B.
What information does IRS Form 14568B require?
The form collects the plan name, Applicant’s EIN, and plan number on each page, lists each missed legislative or regulatory deadline in Section I, describes the correction method in Section II, and lists required enclosures in Section IV.
How do I complete IRS Form 14568B?
Enter the plan name, Applicant’s EIN, and plan number at the top of every page. In Section I, check each applicable failure—pre‑approved plan deadlines, individually designed plan cycles, or other non‑amender failures. Attach the signed amendments, prior plan document, and any determination letter as listed in Section IV, then sign the form. Submit the completed statement with the required attachments.
Do I need to list every missed deadline for pre‑approved plans?
The form lists multiple Cumulative List deadlines, so filers may be unsure which apply. Verify that the plan’s missed adoption date matches one of the listed deadlines (e.g., April 30 2010, April 30 2012, April 30 2016, July 31 2020, July 31 2022).
Can I use Form 14568‑B for a retirement plan that isn’t an IRC 401(a) plan?
The title and purpose specify IRC 401(a) plans only. Confirm the plan is classified as an IRC 401(a) plan before filing.
Are individually designed plans that weren’t under the 5‑year remedial cycle before 1 Jan 2017 required to report here?
Section B limits coverage to those subject to the 5‑year cycle prior to that date. Check the plan’s amendment cycle start date; if after 1 Jan 2017, this form does not apply.
Where should I attach additional pages for Section I.B.?
The source requires specific labeling of attachments. Label each attachment “Section I.B. of Form 14568‑B, Identification of Failures, The Changes required by the Cumulative List” and include plan name, EIN, and plan number at the top.
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