For decades, employer retirement plans had a formal way to confess and fix their mistakes, and IRAs had nothing. A plan sponsor who misapplied a vesting schedule could walk into the Employee Plans Compliance Resolution System. An IRA owner whose custodian botched a required distribution had no comparable door — just a private letter ruling request, or silence and hope.
On October 22, 2026, Treasury and the IRS closed that gap with Revenue Procedure 2026-33, establishing the IRA Compliance Resolution System (ICRS). A companion procedure, Rev. Proc. 2026-34, rewrote EPCRS for employer plans and took effect immediately. ICRS does not open until May 1, 2027.
The coverage has been warm, and the gap it fills is real. But before you file anything, read the eligibility rules — because the program is considerably narrower than "the IRS will help you fix your IRA mistake," and the Revenue Procedure itself tells you where the free alternatives are.
Four Failures, and Only Four
At launch, ICRS consists of a single component: the IRA Voluntary Correction Program (IVCP). Appendix A lists exactly four eligible failures, and the text is blunt that "IVCP is not available to correct any failures outside of" that list:
- RMD Failure — less than the required minimum was distributed
- IRA Establishment Failure — you asked for one type of IRA and got another
- Nonspouse Beneficiary Distribution or Rollover Failure — an inherited IRA was improperly distributed or rolled over
- 60-Day Rollover Failure — the rollover window was missed
Notably absent: excess contributions, botched Roth conversions, prohibited transactions, valuation problems. Those still route through the Voluntary Closing Agreement Program or nothing at all.
The Catch: Someone Else Has to Have Erred
Here is the structural limitation that most summaries skip. For three of the four failures, the definitions require that the error occurred "due to a failure by a Service Provider." Your own forgetfulness does not qualify.
"Service Provider" is defined as a professional with a service contract or agreement in place — an IRA custodian, certified financial planner, fiduciary financial adviser, CPA, or licensed attorney. A self-directed IRA owner who simply forgot to take an RMD has no Service Provider to point to.
The RMD door is narrower still. To be eligible, the Service Provider must have had established practices and procedures "reasonably designed to promote and facilitate overall compliance," those procedures must have been "routinely followed," and the failure must have occurred through an oversight or mistake in applying them. A custodian with no compliance process at all fails this test — which, perversely, leaves its customers with no ICRS remedy.
The one exception is the 60-day rollover: the procedure states plainly that such a failure "does not need to have occurred due to an error by a Service Provider."
The $3,500 Question
The user fee for a regular IVCP submission is $3,500, due at filing through Pay.gov. Group submissions by custodians start at $10,000 for the first 10 affected owners, add $250 per owner beyond that, and cap at $50,000. Fees for submissions filed after December 31, 2027 will be reset annually. Anonymous submissions are not permitted, and the IRS reserves the right to decline a case "in the interest of sound tax administration."
Now set that against what Rev. Proc. 2026-33 concedes in Section 3.03. For a missed RMD, the section 4974 excise tax can be waived with no user fee under Treas. Reg. § 54.4974-1(g) — the reasonable-cause request made on Form 5329. For a blown rollover, self-certification under Rev. Proc. 2020-46 and Rev. Proc. 2016-47 is, in the procedure's own words, "available at no cost."
Self-certification is genuinely easy: twelve permitted reasons including a financial institution error, a misplaced and never-cashed check, serious illness or a death in the family, a postal error, or a deposit into an account you mistakenly believed was an eligible plan. No IRS approval is needed. You write the certification, give it to the receiving custodian, and complete the contribution within 30 days of the obstacle clearing.
So the two failures ordinary savers are most likely to hit — a missed RMD and a late rollover — both have a $0 path that ICRS explicitly does not replace.
When the $3,500 Is Worth It
ICRS earns its fee where the free routes run out. Self-certification covers only the twelve enumerated reasons; if your facts fall outside them, IVCP replaces a private letter ruling request. A multi-year RMD shortfall, an inherited IRA wrongly collapsed by a custodian, or a Roth-versus-traditional mix-up at account opening are the cases built for this program. The payoff is a compliance statement that is binding on the IRS — real protection that a self-certification does not provide, since self-certification is not itself an IRS waiver.
Practical Takeaways
Try the free door first. If you missed an RMD, file Form 5329 with a reasonable-cause statement before considering a $3,500 submission. If you missed a rollover deadline for one of the twelve listed reasons, self-certify.
Document who told you what. Because three of the four failures hinge on a Service Provider's error, contemporaneous records matter — the procedure specifically contemplates written summaries of oral communications with your adviser or custodian.
Watch the refund clock, not the filing clock. Filing an IVCP submission does not extend the statute of limitations on refunds. If a correction should produce a tax refund and your three-year window is closing, file a protective claim; relief under ICRS does not resurrect a closed tax year, and any refund still requires an amended return.
Nothing is fileable until May 1, 2027. Errors discovered now should be addressed through existing channels rather than held for the new program.
Sources: IRS Revenue Procedure 2026-33 (IRA Compliance Resolution System); IRS Revenue Procedure 2026-34 (EPCRS); IRS Newsroom, "Treasury, IRS update retirement plan correction program and establish correction program for individual retirement accounts"; IRS Revenue Procedure 2020-46; Treas. Reg. § 54.4974-1(g)