Editorial Standards
How we research, review, and update this guide
Every Accountably guide is researched against primary IRS sources, reviewed by a U.S. CPA, and refreshed as guidance evolves. Read our Editorial Guidelines to see how we source, fact-check, and update our content.
The fix ran through the IRS Voluntary Correction Program. The schedule that mattered most that day was Form 14568-B. Once we got the story straight, packed the right narratives, and filed through Pay.gov, the noise calmed and the clock stopped feeling like a threat.
If you are here because you need to use Form 14568-B, you likely want three things, a clear checklist, zero format mistakes, and a submission the IRS can approve without a volley of questions. You will get all three below.
Key Takeaways
- Form 14568-B is the IRS’s model schedule for nonamender failures for IRC 401(a) plans, it is Schedule 2 in the Form 14568 series. You cannot change its format or content.
- Use it as an attachment to Form 14568, the Model VCP Compliance Statement, inside a complete VCP submission; it is not filed on its own. Include concise narratives of facts, failures, corrections, timing, affected participants, and safeguards.
- You must open a VCP case electronically with Form 8950 via Pay.gov. Form 8951 is only for additional user fee payments on an open VCP case.
- Keep your combined PDF under 15MB, then fax overflow documents with your Pay.gov Tracking ID if needed.
- Typical processing time is roughly 4 to 6 months once the IRS accepts your complete package.
What Form 14568-B actually covers, and when you should use it
The “what”
Form 14568-B is the IRS model schedule for,
- Nonamender failures for IRC 401(a) plans. The IRS lists it as “Schedule 2” in the 14568 series. The title matters because it guides what you write and which enclosure list you follow. Do not relabel or reformat the PDF. Use it as issued.
The “when”
Use 14568-B when your correction narrative centers on plan document timing, restatements, or missed amendments that place the plan out of qualification. If your failure sits in a different bucket, pick the matching schedule, for example loans, RMDs, or 402(g) excess deferrals. You attach 14568-B to Form 14568 inside your VCP PDF, since the schedule is designed to accompany the main 14568 form and is not filed on its own. Include the required narratives with it.
The “why”
Two reasons, structure and speed. The schedule’s fixed fields force consistency across submissions, which shortens review time and reduces follow up. The IRS says not to modify the format or content of these model forms, so you avoid a silent rejection risk by staying within the lines.
Build the model VCP package around 14568-B
Here is the clean, repeatable way to package a VCP submission that uses 14568-B.
- Open the case on Pay.gov with Form 8950
- Create or sign in to your Pay.gov account, search “8950,” complete the application, and pay the user fee based on plan assets. As of December 4, 2025, Form 8950 and fees are electronic only.
- Assemble a single PDF under 15MB for upload
- Combine Form 14568, Form 14568-B, all narratives, calculations, sample computations, and any supporting plan documents. Form 14568-B is not filed on its own, so it must attach to Form 14568 in the submission. Keep it under 15MB, then fax overflow pages with the Pay.gov Tracking ID to the IRS VCP fax line if needed.
- Include power of attorney or information authorization if needed
- Add Form 2848 if you want a representative to advocate, negotiate, and sign where permitted. Use Form 8821 if you only want a third party to receive information and copies of correspondence. The IRS differentiates their authority, so match the form to the job.
- Expect a review window of about 4 to 6 months
- Once complete, the IRS assigns a specialist. On approval, you receive a signed version of your Model VCP Compliance Statement. Keep it with your signed plan documents, it is your proof of good faith correction.
A quick note on money, if the initial user fee payment fails or was miscalculated, do not resubmit a new 8950. Use Pay.gov Form 8951 to make an additional payment tied to the existing control number.
How to write winning narratives for 14568-B
Think about your narratives like a three-act story. You state what went wrong, you show how you corrected every affected person with math that others can retrace, and you prove how you will keep it from happening again. Keep paragraphs short, label numbers clearly, and front load the facts.
The must-have elements
- Facts and discovery date Summarize how you discovered the issue and when. Identify the plan, the plan number, and relevant dates tied to missed amendments, restatements, or late adoption. This goes into Section I of the model 14568 package.
- The failure Reference the qualification rule that was missed and the period of noncompliance. Avoid jargon. If it is a nonamender failure, say which document, which cycle, and the date it should have been signed. If it is a late amendment adoption, state the timeline.
- Corrections, with math Show, do not tell. Attach calculations, sample computations, and any corrective amendments. Label earnings methods. If you corrected contributions, show how you computed earnings. If you corrected documents, attach the executed amendment or adoption documents, and remember the corrective amendment must be adopted retroactively to the original effective date of each missed provision, since a prospective-only amendment does not cure a nonamender failure.
- Affected participants Count them, name categories if needed, and explain your outreach plan for former employees and beneficiaries, if applicable. The IRS expects this content inside the model template.
- Safeguards Explain procedures you put in place to prevent recurrence, for example document calendar controls, service provider checks, or board adoption workflows with dated sign-offs. The model 14568 prompts you to include this.
Tip, write for a reader who does not know your plan. If a stranger can follow your math and your timeline in one read, you likely built a strong submission.
File format discipline that saves time
- Do not edit the layout of Form 14568-B or any 14568 schedule. Fill the issued PDF and attach narratives as separate, clearly named pages. The IRS says the format and content may not be modified.
- Keep a consistent file naming convention, for example “PlanName_14568-B_Narrative_Facts.pdf” and “PlanName_Calculations_Samples.pdf.” It shortens review time and internal QC.
- Keep totals near the top of the page, then show the detailed lines below. Reviewers scan before they dive.
The core documents in your VCP file
Here is the minimum set most 14568-B cases need.
- Form 8950, created and signed on Pay.gov, which creates your Pay.gov Tracking ID and handles the user fee.
- Form 14568, Model VCP Compliance Statement, which Form 14568-B attaches to and is not filed without.
- Form 14568-B, Schedule 2, fully completed.
- Narrative attachments covering facts, corrections, timing, affected participants, outreach, and safeguards.
- Calculations and sample computations, plus corrective plan amendments or adoption documents, where relevant.
- Form 2848 or Form 8821 when you want representation or information access, matched to your needs.
Fees and payment, quick primer
VCP fees are based on total plan assets. As of the IRS page last reviewed August 26, 2025, the standard fees are below. Pay on Pay.gov during the 8950 flow, and use 8951 if you owe more later.
| Plan assets | VCP fee |
| $0 to $500,000 | $1,500 |
| Over $500,000 to $10,000,000 | $3,000 |
| Over $10,000,000 | $3,500 |
Common mistakes the IRS calls out, paying the wrong fee, submitting multiple Pay.gov 8950s for the same case, and incomplete PDFs. If something goes sideways, call the VCP status line and use Form 8951 for new payments tied to the open case.
Where execution breaks, and how to prevent it
You know the usual suspects, peak season overload, unclear review roles, and missing documents. The fastest way to cut rework is to treat VCP packaging like month end close, with an SOP, internal checklists, and final file owner. If your firm needs help building that discipline into delivery, Accountably can integrate standardized workpapers and review steps into your workflow so submissions move quickly without risking format errors or missing supports. Use that support sparingly and only when you really need it.
Pick the right schedule, quick cheat sheet
Use this table to match common failure types to the IRS model schedules. Always verify your facts against the current IRS titles.
| Schedule | Title on IRS list | Typical use case | Watch outs |
| 14568-A, Schedule 1 | Plan Document Failures for 403(b) Plans | Any 403(b) plan document failure, including a missed written-plan requirement or late interim amendment | Confirm the precise plan document defect and its effective date |
| 14568-B, Schedule 2 | Nonamender Failures for IRC 401(a) Plans | Missed restatements and late plan amendments | Attach executed corrective amendments, date the adoption correctly |
| 14568-C, Schedule 3 | SEPs and SARSEPs | SEP or SARSEP document or operation failures | Fees or sanctions can differ for IRAs in limited cases |
| 14568-D, Schedule 4 | SIMPLE IRAs | SIMPLE eligibility or document issues | Include the correct SIMPLE document, Form 5304-SIMPLE or 5305-SIMPLE if applicable |
| 14568-E, Schedule 5 | Plan Loan Failures | Loans with missed payments, spousal consent, terms | Follow the IRS loan correction menu precisely |
| 14568-F, Schedule 6 | Employer Eligibility Failure, 401(k) and 403(b) | Employer was not permitted to sponsor the plan type | Provide clear employer status evidence |
| 14568-G, Schedule 7 | Excess deferrals over 402(g) | Elective deferrals above the limit | Show timely distribution or corrective math |
| 14568-H, Schedule 8 | RMD failures | Late or missed required minimum distributions | Do not use for beneficiary-only cases, use 14568 with narratives instead |
| 14568-I, Schedule 9 | Limited Safe Harbor by Plan Amendment | Narrow safe harbor fixes by amendment where allowed | Include the corrective amendment and timing proof |
Form 14568, the anchor document
When you use the model compliance statement, it acts as the spine of your submission. It identifies the plan, lays out the failures, and references each attached schedule and narrative. The IRS encourages you to use it and to keep its format unchanged.
Filing flow, end to end
- Create the Pay.gov 8950, pay the fee, and save the Pay.gov Tracking ID.
- Build one combined PDF with 14568, your chosen schedules, and all narratives. Keep it under 15MB, then fax overflow documents to the VCP fax line with your Tracking ID if needed.
- If payment fails or the fee changes, use Pay.gov Form 8951 to add funds to the open control number, never open a duplicate 8950.
- Expect about 4 to 6 months for a compliance statement, then file it away with your signed plan documents.
Final review checklist for 14568-B submissions
Use this checklist before you hit Submit on Pay.gov.
- Plan identifiers match your latest Form 5500 series filing, including sponsor name and plan number, and the plan name, Applicant's EIN, and plan number appear at the top of every page of the compliance statement and every attachment.
- Form 14568-B is correctly labeled as Schedule 2, completed without any edits to the PDF layout.
- Narratives cover facts, failure, correction, timing, affected participants, outreach, and safeguards, with labeled computations and any corrective amendment attached.
- Combined PDF is under 15MB, overflow is ready to fax with the Pay.gov Tracking ID on the cover sheet.
- Power of attorney or information authorization included where needed, 2848 for representation, 8821 for information only.
- VCP fee amount matches plan assets. If a fix is needed after submission, plan to use Form 8951 rather than opening a duplicate 8950.
- Internal SOP confirms who owns the file, who signs off on math, and who verifies that the schedules match the narratives.
Delivery discipline that keeps you out of trouble
You do not have a sales problem, you have a delivery system problem when submissions bounce for preventable issues. The fastest path to fewer IRS questions is structure, standard file names, clean workpapers, and a single owner for the final PDF. If your firm is buried in production and wants to protect review time, you can bring in help to standardize workpapers and documentation flow inside your own systems. Accountably supports firms that need disciplined, secure execution without giving up control of their workflow.
Short compliance notes
- EPCRS is currently set out in Rev. Proc. 2021-30, and the IRS pages you used above were last reviewed in 2025. Always check for the latest annual revenue procedure that sets fees or references, and cite the review date in your cover memo.
- VCP is all electronic via Pay.gov for Form 8950 and Form 8951 as of 2019. Save the Pay.gov receipt and Tracking ID with your file.
- For RMD failures, consider Schedule 14568‑H rules that limit when you can use that schedule for beneficiaries.
Micro‑templates you can copy
Section I, facts and failure
“We discovered on [date] that the plan document was not timely amended for [law change], which became effective on [date]. The plan sponsor intended to adopt the required amendment by [deadline], however, due to [process gap], adoption occurred on [actual date]. The affected period is [start] through [end]. The failure affects [count] participants.”
Section II, correction summary
“On [date], the sponsor executed a corrective amendment effective [date]. No change in participant benefits occurred, and operational history matched the corrective language. No corrective contributions were required. We enclose the executed amendment and attorney opinion letter. We will notify affected participants by [method] no later than [date].”
Section III, safeguards
“The sponsor implemented a document calendar with quarterly legal review, a board sign‑off template with dated signature blocks, and a service provider checklist tied to the current remedial amendment cycle. The plan’s document owner will certify status each quarter to the CFO.”
Common Mistakes We See Every Season
Across VCP submissions, the same handful of 14568-B errors trigger IRS follow-up and stall a case. Here are the ones my team catches most often, with the fix we paste into our review SOP.
Reusable Checklists
These are copy-paste ready for your firm SOP. Drop them into your VCP workpaper template so every 14568-B case clears the same review gates before it reaches Pay.gov.
Section I: identify and classify the failure
- Confirm the issue is a nonamender failure under IRC 401(a), not a different EPCRS failure that needs another schedule.
- Decide whether the plan is pre-approved (Section I.A) or individually designed (Section I.B).
- For pre-approved plans, match the missed Cumulative List to the correct plan type and adoption deadline before checking a box.
- For individually designed plans, split failures by period: Cumulative List before January 1, 2017, Required Amendments List on or after that date.
- Use Section I.C for favorable determination letter conditions or any Other nonamender failure, described in a labeled attachment.
Correction and Sections II to IV
- Adopt each corrective amendment retroactively to the original effective date of the missed provision.
- Enclose signed and dated copies of every corrective amendment used (Section IV).
- Enclose the plan document in effect before the corrective amendments (Section IV).
- Enclose the most recent determination letter only if the plan has received one (Section IV).
- Certify retroactive adoption in Section II and describe a recurrence-prevention procedure in Section III, never leaving it blank.
Package assembly and identifiers
- Attach Form 14568-B to Form 14568 as part of one VCP submission, not as a standalone filing.
- Include the user fee and Forms 8950 and 8951 as required by the current EPCRS Revenue Procedure.
- Put the plan name, Applicant's EIN, and plan number at the top of every page, including all attachments.
- Use the issued PDF without altering its format or content.
- Cross-check that every schedule referenced in the package matches a narrative in the file.
Keep 14568-B Season From Stalling
VCP work does not arrive on a tidy calendar. A nonamender failure usually surfaces at the worst moment, during a pre-approved plan restatement, a plan acquisition, or an IRS examination, and the clock on each missed Cumulative List is already long expired. By the time a sponsor reaches us, the 2012 Cumulative List deadline of July 31, 2020 for defined benefit plans or the 2017 Cumulative List deadline of July 31, 2022 for defined contribution plans (per Announcement 2020-7) is often years in the past, with retroactive amendments still to be drafted.
The bottleneck is rarely the law, it is assembly. Each 14568-B case needs the right Section I boxes, retroactive amendments dated to each provision, labeled narratives, and identifiers on every page, and that detail work competes with everything else on the desk. Structured production is what keeps these submissions moving.
- Standardize how preparers classify the failure into Section I.A, I.B, or I.C before any drafting begins.
- Template the Section I.B attachment labels and the Required Amendments List versus Cumulative List split so nothing is misfiled.
- Build a tracker that ties each corrective amendment to its original effective date for the Section II certification.
- Run a two-pass review on identifiers, confirming the plan name, Applicant's EIN, and plan number on every page and attachment.
- Hold the package until Section III actually describes a recurrence-prevention procedure.
That is the kind of disciplined, documented execution we build into a firm's workflow. Our tax execution support standardizes the workpapers, review passes, and file ownership so VCP submissions leave the office complete the first time.
FAQs
What does Form 14568-B cover?
Form 14568-B is Schedule 2 of the Model VCP Compliance Statement, covering nonamender failures for IRC 401(a) plans. You use it to document and correct a plan that was not timely amended for required law changes as part of a Voluntary Correction Program submission.
Can Form 14568-B be filed on its own?
No. Form 14568-B is a schedule that attaches to Form 14568, the main Model VCP Compliance Statement. You file it together with Form 14568, Form 8950, and the user fee in a single PDF uploaded through Pay.gov, never as a standalone form.
What identifiers go on each page of Form 14568-B?
Show the plan name, the Applicant’s EIN, and the plan number on each page of the compliance statement, including every attachment. Use the employer’s EIN, never a Social Security number, and keep the identifiers consistent across the package.
How long will my VCP take?
The IRS commonly cites a window around four to six months from submission acceptance to a signed compliance statement, assuming a complete package. Complex cases or incomplete PDFs can extend this timeline.