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New Year, New Fees: VCP and Determination Letter Fees Increase in 2026

  • Allison Martinez, née De Tal & Milton Heber
  • 2 days ago
  • 2 min read

The IRS recently released Revenue Procedure 2026-4, which increases various user fees, including for Voluntary Correction Program (“VCP”) applications and determination letter applications.


Voluntary Correction Program (VCP) User Fees

Effective January 1, 2026, VCP submission fees at all levels increased by $500 and are:

Plan Assets

Fee

$500,000 or less

$2,000

Over $500,000 to $10,000,000

$3,500

Over $10,000,000

$4,000

Fees for group VCP filings have increased from $10,000 to $13,500.


Determination Letter User Fees

Fees for determination letter applications have also increased:

  • From $2,700 to $4,000, for Form 5300 (for all qualified plans and for 403(b) plans with 100 or more participants)

  • From $300 to $500, for Form 5300 (for 403(b) plans with less than 100 participants)

  • From $1,200 to $2,000, for Form 5307 (relating to preapproved plan modification)

  • From $3,500 to $4,500, for Form 5310 (relating to plan terminations)


Other Updates

Determination letter requests made by filing Form 5300 series are now required to be submitted electronically on www.pay.gov.


Please reach out to our attorneys if you have questions about the updated fees.



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© Boutwell Fay LLP 2025, All Rights Reserved. This handout is for information purposes only and may constitute attorney advertising. It should not be construed as legal advice and does not create an attorney-client relationship. If you have questions or would like our advice with respect to any of this information, please contact us.



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