IRS Eases Rules on Pension Plans’ Use of Custom Mortality Tables

The Internal Revenue Service has issued new guidance that gives some defined benefit pension plans relief from having to reapply for approval of their plan-specific mortality tables, potentially saving time and administrative costs ahead of looming 2026 deadlines.

“This revenue procedure provides immediate relief for some of those plan sponsors by narrowing the category of plan sponsors that are required to request approval of new plan-specific substitute mortality tables,” the IRS guidance states.

In the guidance, released in May, the IRS modified prior rules that required plans with significant shifts in participant populations—including gender shifts in the plans’ participant count—to terminate their use of plan-specific substitute mortality tables and apply for new ones.

These tables, used to calculate the present value of liabilities and funding obligations, must be approved by the IRS if they deviate from the generally applicable mortality tables.

Under the new rules, plans that base their mortality tables on a combined male-and-female mortality rate can continue using their existing tables—even if the number of men or women in the plan has shifted significantly—as long as the total number of participants stays roughly stable.

Specifically, the total participant count must remain between 80% and 120% of the average number of participants the plan had during the past years used in its mortality experience study.

Plan actuaries, however, must certify in writing that the tables still accurately predict mortality for the combined population.

The Department of the Treasury and the IRS determined that requiring reapproval based solely on shifts in gender counts, despite stable overall plan numbers, created unnecessary compliance burdens for sponsors.

The relief applies to plan years beginning on or after January 1, 2026.

The change stems from President Donald Trump’s February executive order directing federal agencies to review and eliminate unnecessary regulatory burdens. The order ostensibly endorses the Department of Government Efficiency, also known as DOGE, that has been tasked with reducing “wasteful government spending” and deregulation.

Much of the reduction has stemmed from slashing the government workforce.

The IRS, for example, had its workforce cut by more than 11,000 employees, or 11%, due to probationary terminations and its deferred resignation program, according to a May 2 report from the treasury inspector general for tax administration.

“The IRS still needs significant reforms to deliver efficient and cost–friendly results for the American People,” U.S. Secretary of the Treasury Scott Bessent said during a House of Representatives appropriations subcommittee hearing on Tuesday. Bessent added that the federal government has cut $2 billion from the agency’s budget “without any operational disruptions.”