- The proposed ICRS permits IRA custodians and owners to correct eligible inadvertent failures caused by custodian or service provider errors.
- The system transitions 60-day rollover waiver requests from private letter rulings to the new ICRS framework.
- Public comments on the new forms and burden estimates must be received by January 4, 2027, to be assured of consideration.
Overview of the Proposed IRA Compliance Resolution System
On November 3, 2026, the Internal Revenue Service published a notice inviting public comments on a new information collection related to the Individual Retirement Account Compliance Resolution System (ICRS). This collection supports Revenue Procedure 2026-33, which establishes ICRS as a correction program for individual retirement accounts and annuities.
The proposed program may be used by IRA custodians and IRA owners to address certain eligible inadvertent failures. These failures must occur due to custodian errors or inadvertent errors by a service provider. The notice emphasizes that the system is limited to these specific types of errors.
ICRS would also change how individuals request waivers of the 60-day rollover requirement. Such requests would transition from private letter ruling procedures under Rev. Proc. 2026-4 to the new ICRS process.
New Forms for Voluntary Corrections and Waivers
To implement the proposed system, the IRS has developed several new forms. Form 15443 would be used by an IRA custodian or owner to apply for the Individual Retirement Account/Annuity Voluntary Correction Program (IVCP) or to request a pre-submission conference.
Form 15745 requires applicants to describe the eligible inadvertent failures they wish to correct and the proposed methods of correction. IRA custodians using this form may also need to outline procedures for locating lost owners or beneficiaries and revisions to administrative procedures.
Additional forms address specific failure types. Form 15745-A covers required minimum distribution failures, proposed corrections, and related relief requests. Form 15745-B addresses nonspouse beneficiary distribution or rollover failures and IRA establishment failures. Form 15745-C is designated for 60-day rollover failures, including proposed corrections and relief.
The notice qualifies that these forms apply only to eligible failures under the terms of the revenue procedure. Not all IRA issues would qualify for correction through ICRS.
Comment Period and Burden Estimates
This is a new information collection with OMB Control Number 1545-NEW. The IRS estimates it would affect 30,750 responses from businesses or other for-profit organizations, with an average time of 1 hour and 16 minutes per response, resulting in 38,909 total annual burden hours.
Written comments on the collection are due by January 4, 2027, to be assured of consideration. Comments may address whether the collection is necessary, the accuracy of burden estimates, ways to enhance information quality, methods to minimize burden, or related costs. They should be sent to Andres Garcia at the IRS or by email, referencing OMB Control No. 1545-NEW.
The IRS uses such comment periods to assess and minimize the impact of its information collection requirements under the Paperwork Reduction Act of 1995. All comments will become public record.
Republic Tax Relief notes that readers with questions about existing IRS tax debt unrelated to this proposed IRA correction program may wish to contact the firm for a free, no-obligation initial consultation to evaluate suitability of its private tax-resolution services for communicating with the IRS.
Practical Implications and Next Steps
The announcement dated November 3, 2026, represents an early step in establishing the ICRS program. Revenue Procedure 2026-33 remains proposed at this stage, and the final scope of eligible failures, correction methods, and relief available will depend on the finalized procedure.
IRA custodians and owners potentially affected by the types of inadvertent errors described should monitor developments. The proposed forms suggest a structured process for voluntary corrections, but details on qualifications and limitations will be critical.
Readers should verify the latest information directly with the IRS, as this notice focuses on the information collection rather than final program rules. Contact details for additional information are provided in the Federal Register notice.
Announcement covered: Nov 3, 2026.
General information only, not individual tax, legal, or financial advice. Rules, deadlines, and eligibility depend on your circumstances. Check current official guidance or consult a qualified professional.
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