Most IRA administrative errors have long had two endings. You absorbed the tax, or you paid for a private letter ruling and waited months for an answer. On October 22, 2026, the Treasury Department and the IRS issued Revenue Procedure 2026-33, which adds a third ending for a short list of those errors beginning in May 2027.
The line the procedure draws is a particular one. It separates mistakes a professional made from mistakes the account holder made, rather than sorting them by how much damage they did. Three of the four items on the list require that a professional engaged with the account caused the problem. The fourth, a rollover that missed its 60-day deadline, carries no such requirement, and it is the one most account holders will recognize.
What the IRS created
The procedure establishes the IRA Compliance Resolution System, or ICRS, as a first step toward giving IRAs the kind of correction framework employer plans have had for years. That framework is the Employee Plans Compliance Resolution System (EPCRS). Congress directed the IRS to extend something similar to IRAs in section 305(c) of the SECURE 2.0 Act of 2022.
One piece of that framework arrives at launch, the IRA Voluntary Correction Program, or IVCP. Every correction runs through a submission to the IRS and a compliance statement signed by the IRS in return. The employer plan system also offers remedies IVCP does not yet include, self-correction most notably. The IRS describes ICRS as a program it expects to expand based on the comments it receives, so self-correction may become available in the future.
The program becomes effective May 1, 2027.
The four failures ICRS can correct
Appendix A of the procedure lists four eligible failures, and nothing outside that list can be corrected under the initial release of IVCP.
| Failure | What happened | Provider error required | Who files |
|---|---|---|---|
| RMD failure | The year's distribution came up short of the required amount | Yes | Account holder or custodian |
| IRA establishment failure | You asked for one type of IRA and a different type, or a non-IRA account, was opened | Yes | Account holder or custodian |
| Nonspouse beneficiary distribution or rollover failure | A beneficiary took a distribution instead of moving the money into an inherited IRA | Yes | Account holder or custodian |
| 60-day rollover failure | A distribution was not redeposited within 60 days | No | Account holder only |
Correction follows one principle across all four, which is to put the IRA back where it would have been. Missed Required Minimum Distributions are distributed with the earnings attributable to them, and the custodian reports the corrective distribution on Form 1099-R as taxable in the year of correction. A wrong-type account is corrected by opening the type you originally asked for and moving the balance and its earnings across, with the new account treated for tax purposes as though it had existed since the original opening date.
The beneficiary correction does the most work of the four. A nonspouse beneficiary who took a distribution they were told could be rolled over can now contribute that amount to a new inherited IRA in the same beneficiary's name. The procedure then treats the money as though it had moved by direct trustee-to-trustee transfer at the time of the original error, which makes the original distribution a nontaxable event.
Why the Service Provider requirement decides most of it
Service Provider is a defined term in the procedure, and the definition is wide. It covers any service professional under a contract or agreement with you or with respect to your IRA, naming a custodian, a certified public accountant, a licensed attorney, a certified financial planner, and a fiduciary financial adviser among others.
For the RMD failure and the establishment failure, the procedure adds a second condition. The provider must have had practices and procedures in place, formal or informal, reasonably designed to promote compliance. Those procedures must have been routinely followed, and the failure must have occurred as an oversight in applying them. A provider operating with no process at all does not put its client inside the program.
What falls outside is the error with no professional behind it. If you reach your RMD required beginning date and simply do not take the distribution, the excise tax of 25 percent on the shortfall, reduced to 10 percent when you correct inside the window, applies exactly as it did before, and relief still runs through Form 5329 with a reasonable cause statement. ICRS changes nothing about that path.
In practice, the wrong-type account is the failure most often caught before it does damage. An IRA opened as a Roth IRA when the account holder asked for a Traditional IRA tends to surface during application review, or when transfer paperwork fails to line up, and it is fixed before money moves. The cases that would need ICRS are the narrower set where a rollover completed first and the error was found afterward.
The 60-day rollover waiver moves out of the private letter ruling process
The fourth failure works differently in two ways. It requires no Service Provider error, and the account holder, not the custodian, is the only party the procedure permits to file.
The underlying rule is unchanged. The 60-day clock on an indirect rollover starts the day you receive the distribution, and money not redeposited before the clock expires becomes taxable income. A 10 percent additional tax applies if you are under age 59 1/2. What changes is where you go to ask for relief. Waiver requests have been private letter ruling territory, which is slow and costly. During 2027 you can use either route. From 2028, the IRS anticipates that ICRS will be the only one.
The facts the IRS weighs are the same ones it has always considered: an error by a financial institution, death, disability, hospitalization, incarceration, restrictions imposed by a foreign country, postal error, whether you used the money, and how much time has passed since the distribution.
The free routes stay open. Automatic waivers and the self-certification process under the earlier revenue procedures are unaffected and still cost nothing. Most 60-day rollover failures trace to something mechanical, a check that was never issued or one that went missing in the mail, and those are the facts self-certification was written to cover.
What ICRS adds is a path for the failures that fall outside standard cases. Self-certification works only if one of the reasons on the IRS model letter prevented the rollover, and only if the money went in as soon as practicable once that reason cleared, usually within 30 days. A delay nobody noticed until the Form 1099-R arrived has already missed that condition. The standard ICRS applies is wider, asking whether denying relief would be against equity or good conscience, and treating elapsed time as one factor rather than a cutoff. Someone whose waiver request has already been denied, which rules out self-certification entirely, now has somewhere left to go.
The two also differ in what you end up holding. Self-certification is a representation rather than a waiver, and the IRS can reject it on audit. ICRS ends in a compliance statement signed by the IRS.
A waiver does not suspend the one-rollover-per-12-month limit, and where the request involves an IRA-to-IRA rollover the submission has to state that no other such rollover occurred in the prior twelve months.
What a submission costs and how it works
A regular submission filed before January 1, 2028 carries a user fee of $3,500. Fees for submissions after that date will be set in the annual Employee Plans revenue procedure for 2028.
The filing runs through Pay.gov on Form 15443, with the fee paid at submission and the supporting documentation uploaded alongside it. What the IRS wants in that documentation is a description of the error, how and why it happened, and the correction being proposed, described in enough detail to show the calculations behind it. Submissions cannot be anonymous. Once a compliance statement is issued, the correction has to be implemented within 90 days.
Custodians can file as well, including a group submission covering at least ten account holders hit by the same systemic error, so a correction may arrive through your custodian rather than starting with you. For a missed RMD the custodian makes the corrective distribution in any event, which means the correction depends on their participation. Among self-directed firms, which are smaller and work closely with their account holders, a compliance statement signed by the IRS will generally give them the confidence to act on your behalf.
What cannot be resolved with ICRS
A prohibited transaction is not on the list. Nothing in ICRS repairs an account disqualified under section 4975. Anything the IRS considers egregious, such as the misuse of IRA assets, or anything connected to an abusive tax avoidance transaction are also not covered. A return already under examination disqualifies you, and you have to be current on your tax filings to participate at all.
The distinction between SEP and SIMPLE plans and SEP and SIMPLE accounts is easy to read past and worth getting right. The employer plan itself, the SEP Arrangement or the SIMPLE IRA Plan, is not eligible for ICRS and continues to be corrected under the employer plan program. The individual accounts, SEP IRAs and SIMPLE IRAs, are eligible. An employer who misses a plan document update still goes to EPCRS. An employee with a missed RMD on their SIMPLE IRA can use ICRS.
Correction also does not reopen a closed tax year. Refunds are available only while the statute of limitations is still open, though relief can still be worth having in a closed year. A nonspouse beneficiary who can no longer claim a refund may still contribute the distributed amount to a new inherited IRA and receive basis for that contribution.
The dates already running
Comments on the procedure are due January 20, 2027, and the IRS has asked specifically which additional errors should be added in future versions. That is the genuine open question in the document, and the people best placed to answer it are the ones who watch these errors happen.
The program opens May 1, 2027.
The wrong-type account carries a deadline of its own, and it is the one to watch. No submission is accepted after December 31 of the year following the year the account was opened. An account opened in 2026 can therefore be corrected only between May 1 and December 31, 2027. One opened in 2027 gets until the end of 2028.
Most account holders will never file under ICRS. The errors it corrects are uncommon when the people handling the account are careful, and the most frequent of the four, the missed 60-day deadline, already has a free remedy covering the ordinary mechanical causes. If you believe your IRA has encountered one of the covered failures, reach out to your licened tax professional for guidance.