Treasury and the IRS issued Notice 2026-49 on August 12, 2026, providing four sample forms and a proposed five-step procedure for direct rollovers to or from a retirement plan. Use of the forms and procedures is optional. The notice carries out section 324 of the SECURE 2.0 Act, which directed Treasury to publish sample forms that simplify and standardize the rollover process. Treasury and the IRS are not currently providing any safe harbor for using them, and comments are due on or before October 23, 2026.

What Notice 2026-49 actually issues

The notice attaches an appendix with four sample forms and a set of proposed rollover procedures and protocols. They are designed to do five things: protect a participant's personal identifying information through encrypted data transfers and a unique rollover identification number (RIN) assigned by the receiving plan, require coordination between the two plans so the participant is not the courier, use a standard set of data terms across the process, require both plans to verify the accuracy and legitimacy of a rollover request before funds move, and push electronic communication and transfer wherever possible.

The RIN is generated as a unique code, such as a 20 digit alphanumeric combination, and both plans are expected to carry it on every form and communication tied to that rollover request.

The five steps

1. The participant submits Form 1, Participant's Rollover Request, including a signed Rollover Request Authorization, to the receiving plan.

2. The receiving plan creates the RIN and submits Form 2, Receiving Plan's Request to Distributing Plan, with the participant's authorization attached.

3. The distributing plan independently verifies the request, then transmits Form 3, Distributing Plan's Rollover Certification, with the account detail and available transfer methods.

4. The receiving plan confirms it can accept the rollover and returns Form 4, Receiving Plan's Rollover Acceptance, selecting the transfer method.

5. The distributing plan transfers the funds using the selected method.

If a check ends up being the only method both plans can use, the notice directs that it be made payable to the receiving plan for the benefit of the participant, carry the RIN in the memo line, and be sent directly to the receiving plan rather than to the participant.

What the notice does not do

Three limits are worth reading carefully before anyone treats this as settled process.

• It does not cover IRA-to-IRA transfers. The forms are not intended for IRA-to-IRA rollovers or transfers. They may be used for rollovers to or from an IRA where the other side is an employer plan.

• It does not create a safe harbor. The notice states plainly that Treasury and the IRS are not currently providing safe harbors based on the use of these forms and procedures. They say they will consider adding them after reviewing comments.

• It does not address the rest of the distribution rules. The forms do not cover other requirements that apply to a distributing plan when it makes a distribution, including spousal consent and required minimum distributions. Those still have to be handled separately.

What Treasury says it is considering next

Section IV of the notice lists guidance under consideration, not guidance issued. It includes amending the regulations under section 1.401(a)(31)-1 to remove Q&A-4, which currently allows a paper check to be sent to the participant to complete a direct rollover, and removing the Situation 2 safe harbor in Revenue Ruling 2014-9. It also floats requiring rollovers to be completed either electronically or by check sent directly to the receiving plan, adding new safe harbors tied to using forms like these, and naming additional impermissible procedures such as requiring a Medallion Signature Guarantee.

None of that is in effect today. The notice acknowledges that any such requirement would need system changes at administrators and trustees, and says such guidance would not be effective until they have been given sufficient time to implement it.

Where this shows up in a firm's workflow

For most firms the near-term item is the comment deadline, not a process change. Nothing here obligates a client's plan to do anything differently right now. Comments are due on or before October 23, 2026, referencing Notice 2026-49, and can be submitted through regulations.gov under docket IRS-2026-0100.

The item worth watching is the paper check question. If a firm has plan sponsor clients, or handles a meaningful volume of rollover paperwork for individual clients, the guidance under consideration would end the practice of mailing a direct rollover check to the participant. That is the change that would actually touch a firm's document intake, because the paper check is usually what generates the phone call, the lost check, and the 60 day clock anxiety. Worth noting now which clients still receive rollover checks by mail, so the answer is on hand if the proposal becomes a rule.

For firms already fielding rollover questions, the practical read on Notice 2026-49 today is short: nothing is required, the standard forms exist if a plan wants them, and there is a comment window open until late October. See how SignalsHQ handles multi-document client intake for where rollover paperwork fits into a firm's review workflow.