FLASHPOINT: HAPPY NEW YEAR FROM THE IRS…USER FEES ARE UP!

By: Ilene H. Ferenczy, Esq.

The IRS just issued Rev. Proc. 2026-4, which outlines user fees for IRS opinion and determination letters and VCP fees, among others.

The new fees are effective as of January 1, 2026.

In particular, the user fees for VCP filings are up $500 at each level:

If a practitioner is making a Group VCP filing (i.e., a filing done for a systematic error that affected many plans), the user fee has gone up to $13,500 from $10,000.

If you are requesting a determination letter of any sort, you will also experience increased fees:

The user fee in relation to obtaining a favorable determination letter for a multiple employer plan has stayed the same at $4,200.

The moral of the story: if you are in the midst of doing one of these submissions, you need to let your client know that the user fee is up $500 from your 2025 estimate.

We at Ferenczy Benefits Law Center hope you had a great holiday season and wish you a New Year that is joyous and prosperous.  But if 2026 raises any retirement plan issues, please call us.  After all, we are your ERISA solution!