Rolling over your retirement account may have just gotten a little easier.
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More than three and a half years after the SECURE 2.0 Act became law, the Department of the Treasury and the IRS have issued guidance to simplify and standardize the rollover process by issuing sample forms for direct rollovers to or from a retirement plan. SECURE 2.0 became law on December 29, 2022, when President Biden signed the Consolidated Appropriations Act, 2023 (P.L. 117-328).
The new guidance, which was published as Notice 2026-49, offers four sample forms and a common five-step process for moving retirement savings between employer plans, or between an employer plan and an IRA. The forms are optional for now, and the IRS is not yet offering a safe harbor for using them. Here’s what you need to know.
What is a rollover?
A rollover is a way to move money from one tax-advantaged retirement account to another without triggering an immediate tax bill. You’d commonly use a rollover when you leave a job and want to move your old employer’s 401(k) or other workplace retirement plan into a new plan or an IRA. You might also use it to consolidate retirement accounts.
When you take a distribution from a retirement account, the amount may be taxable unless an exception applies. A rollover allows you to move eligible retirement savings to another retirement account while generally preserving their tax-deferred status. With a direct rollover, the money moves from your old plan directly to the receiving plan or IRA rather than being paid to you first. That not only makes things simpler, it can also help avoid some of the withholding and timing issues that can arise when you receive the distribution yourself.
The guidance from IRS, in the form of Notice 2026-49, focuses on these direct rollovers to or from retirement plans. The guidance and sample forms are not intended for transfers from one IRA to another.
Do the new forms change the tax rules?
No, the new forms don’t change the basic tax rules for rollovers. An eligible distribution that is properly rolled over generally isn’t included in income, and that remains the same. The notice focuses on how direct rollovers are processed, rather than creating a new kind of rollover or changing which distributions qualify.
Does this change my RMD or other requirements?
No. Your required minimum distribution (RMD) is the minimum amount that generally must be withdrawn each year from certain retirement accounts once you reach the applicable RMD age. An RMD isn’t an eligible rollover distribution, so an amount that must be distributed for the year can’t simply be rolled over to another retirement account. Notice 2026-49 makes clear that its new sample forms and procedures don’t replace those underlying distribution rules.
How does Treasury suggest this should work?
Under the proposed procedure, you would give Form 1, the Participant’s Rollover Request, to the plan or IRA receiving the money. That authorizes the receiving plan to contact the old plan and coordinate the rollover on your behalf. From there, the two plans exchange Forms 2 through 4, verify the rollover, and arrange the transfer. Your authorization expressly permits the two plans to coordinate and requires the receiving plan to notify you if there is a problem.
That’s a lot of forms! Is this all on paper?
No, and the IRS would prefer that it not be. The agency wants plans to communicate and transfer the money electronically whenever possible. If electronic transfer isn’t available, the proposed procedure calls for the distributing plan to make a check payable to the receiving plan for your benefit and send it directly to the receiving plan, rather than mailing it to you and having you forward it.
That change is intentional. The Government Accountability Office (GAO), Congress’s nonpartisan watchdog, has identified paper checks as one of the problems with the existing rollover system. In a 2024 report, GAO found that nearly one-third of surveyed participants received paper rollover checks that they then had to send to the receiving plan themselves. That can mean lost or misplaced checks and time during which the money isn’t earning interest or dividends.
Do I have to roll over an entire account?
You can roll over all or part of an account. Form 1 allows you to choose the entire account, the entire pre-tax amount, the entire Roth amount, or specified amounts. It also makes clear that the character of the retirement savings—pre-tax or Roth—remains the same through this process.
What about an IRA-to-IRA rollover or transfer?
The guidance applies when at least one side of the transaction is an employer plan—so, for example, a rollover from an old 401(k) to an IRA or from an IRA into an employer plan. It does not apply when both the distributing and receiving accounts are IRAs, which Treasury notes are commonly handled through the existing ACATS electronic-transfer system.
Do plans have to use these forms?
No. For now, plans may use the sample forms and procedures, modify them as necessary, incorporate them into their own systems or use different forms altogether. But Notice 2026-49 does not require the use of these forms.
What about a safe harbor?
Using the forms doesn’t currently give a plan a special IRS safe harbor. But Treasury and the IRS are considering whether future guidance should provide safe harbors for plans that use standardized forms. For example, a receiving plan might be permitted to rely on the forms to conclude, absent evidence to the contrary, that the distributing plan is tax-qualified and the rollover is valid.
Where can I see the guidance and sample forms?
The guidance is in the form of an IRS Notice (2026-49), available online. The sample forms are in the Appendix, at the back of the Notice.
Is that all?
No. Bigger changes could be coming. Treasury and the IRS are considering future guidance that could further push the rollover process toward electronic transfers, eliminate the practice of sending direct-rollover checks to participants, and restrict some burdensome requirements that can slow down rollovers. For now, however, those changes are only under consideration.
