IRS Updates EPCRS Guidance

On Sept. 28, 2018, the IRS released Revenue Procedure 2018-52, which incorporates changes to the Employee Plans Compliance Resolution System (EPCRS). As background, EPCRS allows retirement plan sponsors to take IRS-sanctioned steps to correct administrative and operational failures in plans. This Rev. Proc. modifies and supersedes Rev. Proc. 2016-51.

This Rev. Proc. mainly updates guidance to include the changes made to the EPCRS procedures over the last few years. Most notably, the IRS will now require employers submitting voluntary correction program (VCP) applications to do so electronically via In transitioning to this policy, the IRS will begin to accept the electronic applications on Jan. 1, 2019. However, employers will be allowed to file electronically or file a paper submission until March 31, 2019.

This Rev. Proc. is effective Jan. 1, 2019. Employers seeking to take advantage of the EPCRS should familiarize themselves with this guidance to ensure they understand the changes in the process.

Rev. Proc. 2018-52 »