If you are staring at an employer eligibility issue in a 401(k) or 403(b) plan, Form 14568-F is your friend. You will use it as the IRS model compliance statement, Schedule 6, to propose the exact correction the IRS expects for this category of failure. It is precise, it is short, and when you follow it closely, it trades anxiety for clarity.
Key takeaways
- Form 14568-F is the IRS Model VCP Compliance Statement, Schedule 6, for employer eligibility failures in 401(k) and 403(b) plans, and you must use the IRS model format. Do not change the language or layout.
- File your VCP application electronically on Pay.gov using Form 8950, attach your PDF package, and pay the fee there. If the fee later needs an adjustment on an open case, Pay.gov uses Form 8951 for additional payments, not for the initial filing.
- The attached PDF should include Form 14568, the relevant 14568 schedules like 14568-F, and all narratives and exhibits, in the order the IRS specifies. Keep the combined file under 15 MB or fax overflow items with the Pay.gov Tracking ID.
- EPCRS remains governed by Rev. Proc. 2021-30, and the IRS continues to promote using the model 14568 series. Anonymous VCP filings ended on January 1, 2022, although you can request an anonymous pre-submission conference.
- Typical processing time for a complete VCP submission is about four to six months. Track status using your Pay.gov Tracking ID, the IRS control number for your case.
Use the IRS model forms as written, file on Pay.gov with Form 8950, and assemble a tight package that matches the IRS’s order, size limits, and signatures. It sounds simple because it is, when you do it in the right sequence.
What Form 14568-F is, and when you should use it
Form 14568-F, Revision 3-2020, is Schedule 6 of the IRS model VCP compliance statement. It exists for one narrow mission, to correct employer eligibility failures in 401(k) and 403(b) plans. In other words, the sponsor did not meet the statutory criteria to maintain the plan. The schedule spells out the IRS-prescribed correction, so your write-up should follow the schedule rather than offer a custom cure.
You will pair 14568-F with the base Model Compliance Statement on Form 14568, plus narrative attachments that describe the facts, the correction, how you will locate former employees, and what you will change operationally so this does not recur. The IRS is clear, you can use the schedules with or without the base 14568, but you may not modify the model forms.
Which plans and which failures qualify
Schedule 6 applies only to 401(k) and 403(b) plans. Do not use it for defined benefit plans, SEPs, SIMPLE IRAs, or SARSEPs. The form itself frames two categories, a 403(b) sponsored by a non 501(c)(3) or non public education organization, and a 401(k) adopted by an employer that did not meet the eligibility requirements to establish a 401(k). If that is your fact pattern, you are in the right place.
Common real world triggers include mergers where the successor’s status was never verified, a misidentified plan sponsor in the adoption documents, or multi-entity groups where controlled group or affiliated service group rules were never analyzed, so the true employer was not the entity named on the plan. The fix runs through 14568-F’s correction method, not a homegrown alternative.
How to file your VCP package in 2025 without backtracking
You no longer mail anything to open a VCP case. You sign in to Pay.gov, complete Form 8950 online, attach one consolidated PDF that contains your 14568 series forms and all exhibits, and pay the user fee. The Pay.gov receipt shows a Tracking ID, and the IRS uses that as your control number. If your PDF is larger than 15 MB, fax the overflow to the IRS with the Tracking ID on the cover.
The IRS’s own HOW-TO pages and submission kits echo the same instructions, including the 4 to 6 month expectation for a complete submission. If you are missing items or your package is substantially incomplete, the case may be returned, which adds weeks. Build it right, the first time.
What to include, and what not to include
- Include Form 14568 and, for employer eligibility failures, Schedule 6 on Form 14568-F, plus your narratives and supporting documents in the order the IRS wants.
- Include Form 2848 if you want a representative to act for you, or Form 8821 if you only want someone copied on correspondence.
- Do not attach an old paper Form 8951. Initial user fees are paid through Pay.gov when you submit Form 8950. If you owe an additional fee for an open case later, Pay.gov provides a special Form 8951 for that purpose only.
A quick note on fees and the governing guidance
The user fee is determined by the current Employee Plans fee schedule referenced in the 8950 instructions. The EPCRS framework itself continues to be set by Rev. Proc. 2021-30, with IRS web guidance reinforcing model form usage and the end of anonymous VCP submissions as of January 1, 2022. Always check the IRS EP pages for any fee or procedural updates before you click submit.
When to choose Schedule 6, and the scenarios we see most often
You should reach for Schedule 6 when the plan sponsor was never eligible to sponsor the 401(k) or 403(b) plan in the first place. Two patterns are common.
- 403(b) plans, adopted by organizations that are neither 501(c)(3) charities nor public educational organizations. That includes well meaning entities that believed their tax status qualified but did not.
- 401(k) plans, adopted by employers that did not meet the eligibility rules for setting up a 401(k). Think of cases where an entity name changed, a shell company was used, or the employer on the documents was not the real common law employer.
Edge cases to avoid
If you are dealing with loans, missed RMDs, or excess deferrals, different schedules apply, not Schedule 6. For SIMPLE IRAs, the IRS has a separate Schedule 4 and even a step by step VCP kit. Staying in your lane matters for speed and acceptance.
Build a clean, complete VCP package
Here is a practical checklist our team uses when we assemble Schedule 6 submissions during peak season. It keeps partners out of review loops and protects turnarounds.
Packaging checklist
- One PDF up to 15 MB that includes, in order, Form 14568, Form 14568-F, required narratives for Sections II through V, plan documents, adoption and amendment pages, and any calculations or participant listings that support your statements.
- Pay.gov Form 8950 completed and electronically signed by an authorized person, with the fee paid and the Pay.gov Tracking ID saved to your case file.
- If a representative will act for you, include Form 2848. If you only want someone copied on correspondence, include Form 8821.
- Overflow documents faxed to the IRS with the EIN, plan name, and Pay.gov Tracking ID on the cover, if your combined PDF would exceed 15 MB.
- Internal sign off that confirms you have not edited any IRS model language or formatting on the 14568 series forms.
2848 vs 8821, what each one does
Use the power of attorney when someone needs to represent you and speak for the plan sponsor. Use the information authorization when you just need the IRS to share correspondence with a third party.
| Form | What it allows | Who signs | CAF number needed at filing? |
| Form 2848, Power of Attorney | Representation before the IRS for the matters listed | Taxpayer, and representative accepts | If no CAF yet, enter “None,” the IRS issues one and you use it going forward |
| Form 8821, Tax Information Authorization | Information sharing only, no representation | Taxpayer | Not required to already have one when filing |
The IRS instructions confirm how to enter CAF details on 2848 if none exists, and the IRS’s CAF pages explain how CAF numbers are assigned the first time you file a third party authorization.
What happens after you submit
After a completeness check, the IRS assigns your submission to a specialist. On approval, the IRS countersigns your model compliance statement, meaning the version of Form 14568, with your Schedule 6 and narratives incorporated, becomes the official compliance statement. Expect roughly four to six months from submission to receipt, and use the Pay.gov Tracking ID if you need to call for status. Keep the signed statement and proof of corrections in your permanent file.
Avoid the three delays that bite during busy season
- Unlabeled exhibits or mismatched plan numbers across forms.
- A PDF that exceeds 15 MB with no follow up fax, which stalls the case file.
- Editing the model form text or formatting to “tidy up,” which risks a return.
E-E-A-T in action, how we keep partner time out of review
In my experience supporting CPA firms that are slammed from January through April, the fastest wins come from discipline, not heroics. We use a two person prep and quality check pattern for VCP packages, a standardized naming convention for the entire 14568 set, and a standing rule that every narrative cross references the document title and page number where evidence lives. That simple structure reduces back and forth, and it keeps partner time focused on the judgment calls only.
Using Schedule 6 step by step for 401(k) and 403(b) cases
Schedule 6 tells you exactly what the correction looks like. For both 403(b) and 401(k) cases, you cease contributions as of a date no later than the VCP filing date, you do not permit new contributions, and plan assets remain in the existing trust, annuity, or custodial account until a permitted distribution event occurs under 403(b) or 401(k), as applicable. Your narrative then explains how and why the failure arose and what will change operationally so it does not happen again.
Map your facts to the form
- Section I, identify the failure precisely, including the years affected and the sponsor’s status.
- Section II, adopt the prescribed correction steps for your plan type and insert the correct cease contribution date.
- Section III, document administrative changes, including governance, checks, and evidence you will retain.
Internal control upgrades the IRS actually appreciates
You do not need a novel control library. You need three practical safeguards that auditors and IRS reviewers can follow.
- Eligibility verification, a one page checklist for new or successor sponsors, signed by counsel or the plan’s internal admin, before any adoption or restatement.
- Controlled group review, a simple worksheet that documents the analysis and the conclusion, with the people who ran the test and the date.
- Naming and filing discipline, a standard for workpaper titles and version control tied to the plan name, EIN, and plan number.
These sound basic because they are, and they cut the risk of repeat submissions.
Access the right form, and skip third party pitfalls
Pull Form 14568-F directly from IRS.gov so you are certain you have Rev. 3-2020 in the official format. If a vendor site is down or provides an editable version, do not substitute it for the IRS PDF. The IRS hosts the current 14568-F and the full set of fill in VCP forms on its retirement plan pages.
If your browser balks at the PDF, clear cache, try another browser, and retry. If the IRS web pages are temporarily unavailable, wait and try again rather than using altered templates.
FAQs
Can you file Form 2848 without a CAF number?
Yes. If a representative does not yet have a CAF number, enter “None” and the IRS will assign one. Going forward, the representative uses that CAF number on future authorizations.
Which IRS form reports a 401(k) distribution?
Form 1099 R reports 401(k) and other retirement plan distributions. The payer files it, and withholding flows through to year end reporting. Check the instructions and codes for accuracy. (General reference only.)
Where do I file Form 4868?
File electronically through IRS e file, or, if you must mail, use the current address in the form instructions for your state and payment status. Always confirm on IRS.gov for the current year. (General reference only.)
Do I include Form 8951 with my initial VCP filing?
No. You open a VCP case on Pay.gov using Form 8950, you attach your package there, and you pay the initial user fee there. If, later, an additional user fee is owed on an open case, Pay.gov provides Form 8951 for that purpose.
Final word, and where Accountably helps
You fix employer eligibility failures by following the model. Use the IRS schedule as written, file on Pay.gov with the right attachments, and give reviewers exactly what they need. If your team is buried in production and reviews are piling up, we can help you standardize the package, keep partners out of the weeds, and protect deadlines without losing control of quality or security. When you are ready, we will work inside your workflow and tools, with documented SOPs, named workpapers, and layered reviews that make VCP submissions repeatable.