Forfeiture Guidance for 2024 and Beyond
In 2023, the Internal Revenue Service (IRS) released proposed regulations for how and when qualified defined contribution plans must use forfeitures. These proposed regulations apply for plan years beginning on or after January 1, 2024. Here’s what you should do.
- Take advantage of the transition relief period. Use forfeitures generated and accumulated before 2024 as if they originated during the 2024 plan year—no matter how they accumulated over previous plan years.
- Use forfeitures by the deadlines. Forfeitures must be used within 12 months of the close of the plan year in which they were created. For example, if your plan year end is December 31, forfeitures from the 2024 plan year must be used by December 31, 2025.
- Use forfeitures to:
- pay plan administrative expenses,
- reduce employer contributions (including restoring conditionally forfeited participant accounts), or
- increase benefits in other participant accounts as described in the plan document.
We’ll share additional guidance as it becomes available. If you have any questions, contact your client service team.
