The U.S. Treasury and Internal Revenue Service proposed a standardized way to handle many direct retirement-plan rollovers in Notice 2026-49, issued August 12, 2026 under section 324 of the SECURE 2.0 Act. The proposal supplies four optional sample forms and a five-step workflow intended to make plan-to-plan, plan-to-IRA and IRA-to-plan rollovers easier to verify and complete. It does not cover IRA-to-IRA transfers, and using the forms would not currently create an automatic legal safe harbor.
What Notice 2026-49 would change
The notice is a proposal, not a mandate. It gives retirement-plan administrators a common set of forms and procedures for a direct rollover when at least one side of the transaction is an employer-sponsored retirement plan. Eligible transaction types include:
- One employer plan to another employer plan
- An employer plan to an IRA
- An IRA to an employer plan
An IRA-to-IRA rollover or transfer is outside the proposal. Plans may adopt the sample process, modify it, or continue using their existing workflow.
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How the proposed five-step rollover process works
The appendix to Notice 2026-49 describes four forms used across five sequential actions.
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- Participant starts the request. The participant submits a rollover request to the receiving plan using Form 1.
- Receiving plan forwards the request. The receiving plan sends the request and standardized information to the distributing plan with Form 2.
- Distributing plan certifies the transaction. The distributing plan checks the participant and transaction information, then returns a rollover certification on Form 3. That certification can identify available transfer methods.
- Receiving plan confirms acceptance. The receiving plan verifies that it can accept the assets and uses Form 4 to select the transfer method.
- Assets are transferred. The distributing plan sends the money or assets using the method selected by the receiving plan.
The design assigns specific verification duties to the two plans instead of leaving the participant to relay every account detail between providers.
Security and electronic-transfer features
The proposed protocol is designed for electronic handling wherever practical. It calls for encrypted electronic data transfers, standardized data fields and verification of both the participant’s information and the legitimacy of the rollover. The receiving plan would assign a unique rollover identification number (RIN) so the records and transfer can be matched across the transaction.
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The notice encourages recordkeepers, custodians and other administrators to build the forms into an application programming interface (API), clearinghouse or similar electronic platform. That could reduce manual rekeying and make status information easier to track, but the notice does not require a particular vendor, software product or technical standard.
If an electronic transfer is unavailable, the proposed fallback is a check payable to the receiving plan for the benefit of the participant, sent directly to that receiving plan. The proposal therefore aims to avoid routing the distribution through the participant even when the electronic path cannot be used.
What the proposal means for participants now
- No required form yet: Participation is optional, so your plan may not use these forms.
- No automatic safe harbor: The IRS and Treasury are not currently promising legal protection merely because a plan uses the samples.
- Ask both plans about their workflow: The receiving plan must be able to accept the rollover, and the distributing plan must be able to verify and send it under its procedures.
- IRA-to-IRA transactions are unchanged by this proposal: They are not included in Notice 2026-49.
Until final guidance changes the rules, participants still need to follow the tax and plan-administration requirements that apply to their particular distribution. A direct rollover generally involves the receiving plan or IRA taking delivery, rather than the participant receiving the payment personally.
Reporting when a distribution is split
The 2026 IRS Instructions for Forms 1099-R and 5498 continue to address direct-rollover reporting. When one distribution is divided between a direct rollover and an amount paid to the recipient, the payer prepares separate Forms 1099-R for the two portions. The proposed forms do not eliminate that reporting framework.
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What Treasury and the IRS are still deciding
The agencies asked stakeholders to comment on whether standardized technology and automated procedures could further simplify and speed rollovers. Issues still under consideration include:
- Requiring electronic transfers or checks sent directly to receiving plans
- Amending existing regulatory and revenue-ruling provisions
- Creating safe harbors for plans that use standardized forms
- Technical standards for APIs, clearinghouses and other automated systems
Comments referencing Notice 2026-49 were requested through Regulations.gov or by mail by October 23, 2026. That deadline is for input on the proposal; it is not an effective date for mandatory forms.
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How the proposed process compares with a provider’s current workflow
Whether the approach is an improvement depends on how a provider handles the following points today:
| Decision point | What to check |
|---|---|
| Transaction scope | Does the workflow support plan-to-plan, plan-to-IRA and IRA-to-plan rollovers, or only some of them? |
| Transfer channel | Are transfers electronic, paper checks, or both? |
| Verification | Which plan verifies eligibility, account details and the legitimacy of the request? |
| Security | Are data encrypted and exchanged through standardized fields? |
| Tracking | Is a unique rollover identification number used? |
| Participant effort | How many forms, calls or manual handoffs must the participant complete? |
| Implementation | What technology, staffing and integration work would adoption require? |
| Legal protection | Does any contractual or regulatory safe harbor apply, rather than being assumed from form use alone? |
Bottom line for readers
Notice 2026-49 is a framework that plans can choose to adopt, not a new rollover requirement. Its four sample forms organize a five-step exchange between the participant, receiving plan and distributing plan, with encrypted data, an RIN and direct electronic or plan-payable check transfers as core design features. Watch for final guidance before treating any of the proposed procedures, electronic requirements or safe harbors as mandatory.
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