1. Introduction: What is Form 14568-H?

IRS Form 14568-H, officially titled Schedule 8 (Form 14568-H) – Model VCP Compliance Statement: Failure to Pay Required Minimum Distributions Timely under Section 401(a)(9), is an official tax compliance document published by the Internal Revenue Service (IRS). It is governed by Employee Plans (EP), an operating unit within the IRS Tax Exempt and Government Entities (TE/GE) Division.

This form serves as an attachment to master Form 14568 (Model VCP Compliance Statement) under the IRS Voluntary Correction Program (VCP). It is used specifically by employers, plan sponsors, and retirement plan administrators to report and correct missed Required Minimum Distributions (RMDs) in employer-sponsored qualified plans and Section 403(b) plans.

2. Purpose of the Form: Why Does Form 14568-H Exist?

Under Section 401(a)(9) of the Internal Revenue Code, tax-advantaged retirement plans must distribute a minimum portion of a participant’s account each year once they reach their Required Beginning Date (RBD), or to designated beneficiaries following a participant’s death. Failing to distribute these required amounts causes a major statutory breakdown that threatens both the plan and the participant:

Preventing Plan Disqualification: Complying with Section 401(a)(9) is a mandatory plan qualification requirement. If a plan fails to pay RMDs, the entire retirement plan can technically lose its tax-exempt status. Form 14568-H cures this defect.
Waiver of Participant Excise Taxes: Individual taxpayers who fail to receive timely RMDs are subject to a harsh federal excise tax under Section 4974. Form 14568-H allows the plan sponsor to formally request a group waiver of this excise tax from the IRS on behalf of all affected participants.
Standardizing Catch-Up Payouts: It establishes a clear, pre-approved framework to calculate the missing distributions, allocate appropriate investment earnings or interest, and distribute the funds immediately.

3. Who Needs to File This Form?

Form 14568-H is completed by employers, business owners, trustees, and third-party administrators (known as plan sponsors) who discover that their plan failed to pay RMDs on time. You should file this form if you meet the following criteria:

You sponsor a retirement plan subject to Section 401(a)(9), such as a 401(k), defined benefit pension, money purchase, profit-sharing, or Section 403(b) plan.
The plan failed to distribute an RMD to one or more participants who reached their Required Beginning Date, or failed to pay required death distributions to beneficiaries within statutory deadlines.
You want to secure an official IRS waiver of the Section 4974 excise tax for affected participants so they do not face individual tax penalties.
You are submitting an electronic Voluntary Correction Program filing via Pay.gov using IRS Form 8950 and master Form 14568.

4. Who Is Exempt / Not Required to File?

Form 14568-H is strictly reserved for employer-sponsored retirement plans. You are exempt or not eligible to file this form under the following conditions:

Individual IRA Owners: Individuals who miss an RMD from a personal Traditional IRA, SEP-IRA, or SIMPLE IRA do not use Form 14568-H. Instead, individuals report the missed RMD and request an excise tax waiver on their personal Form 1040 using IRS Form 5329.
Fully Compliant Plans: Plans that calculate and distribute all participant and beneficiary RMDs by statutory annual deadlines have no need for this form.
Plans Addressing Other Failures: If your plan experienced loan errors, missed legal amendments, or excluded employees, you must use other VCP schedules, such as Form 14568-B or Form 14568-E.
Plans Under IRS Examination: If the IRS has notified your business that the retirement plan is under an Employee Plans audit, you cannot use VCP. Those failures must be negotiated through the Audit Closing Agreement Program (Audit CAP).

5. When to File: Deadlines and Frequency

Form 14568-H is an event-based submission rather than an annual recurring filing. You complete and submit it as soon as your annual plan administration testing or internal audit reveals that mandatory distributions were missed.

The submission must occur before the IRS initiates an audit of the plan or sponsor. Once an audit notice is received, the opportunity to request group excise tax relief under VCP is lost. After the IRS approves the submission and signs the compliance statement, the plan sponsor generally has 150 calendar days from the date of the compliance statement to calculate earnings, distribute all catch-up payments, and finalize internal tracking procedures.

6. Where and How to File

Form 14568-H cannot be filed through ordinary mail for initial submissions. It is handled entirely through the federal government’s digital filing portal:

Pay.gov Electronic Submission: Complete Form 14568-H as an attachment to master Form 14568. Merge these forms, participant census worksheets, and earnings calculations into a single PDF package and upload it via Pay.gov alongside Form 8950 (Application for Voluntary Correction Program).
Electronic User Fee Payment: The mandatory VCP user fee—which is determined by the total net assets in the retirement plan—must be paid electronically via Pay.gov at the time of submission.
Supplemental Information: If the assigned IRS Employee Plans specialist requests additional census records or calculations, submit them through secure electronic channels or deliver them to the designated IRS address as per instructions provided by the specialist.

7. Step-by-Step Instructions to Fill Form 14568-H

Form 14568-H provides standardized language to document missed distributions, outline make-whole calculations, and request statutory excise tax relief. The table below outlines its primary sections.

Section	Title	Required Information
Header	Plan & Sponsor Details	Plan name, Employer Identification Number (EIN), and 3-digit plan number (on every page).
Section I	Identification of Failures	Tax years affected, number of participants/beneficiaries involved, and total missed distribution amounts.
Section II	Description of Proposed Correction	Confirmation of catch-up distributions plus earnings (for DC plans) or interest (for DB plans).
Section III	Request for Section 4974 Relief	Formal request that the IRS waive the participant-level excise tax for all affected individuals.
Section IV	Administrative Procedures	Narrative describing automated age-tracking systems and TPA controls to ensure future RMD compliance.
Section V	Enclosures	Checkboxes for attached participant lists, calculation worksheets, and plan document excerpts.

Header: Plan and Employer Information

Enter the complete legal name of the retirement plan, the plan sponsor’s nine-digit Employer Identification Number (EIN), and the three-digit plan number (such as 001). Federal rules require this exact header to appear at the top of every page of Form 14568-H and all attached calculation sheets.

Section I: Identification of Failures

Identify the exact scope of the RMD failures that occurred in your plan:

List each calendar year in which the plan failed to distribute required minimum amounts.
State the total number of participants and beneficiaries affected in each tax year.
Enter the total dollar amount of missed RMD distributions across all affected individuals for each year.

Section II: Description of Proposed Method of Correction

Confirm the standardized correction methods required by the IRS under EPCRS:

Defined Contribution Plans (e.g., 401(k)): The plan will distribute the missed RMD amounts to each affected participant or beneficiary, adjusted for allocable investment earnings (or losses) from the date the payment was due through the date of actual distribution.
Defined Benefit Plans: The plan will make a lump-sum catch-up distribution of all missed annuity payments, plus interest calculated at the plan’s actuarial interest rate, and adjust future monthly annuity payments to the correct level.

Section III: Request for Relief from Section 4974 Excise Tax

This is the most critical section for participant protection. You will check the box requesting that the IRS grant relief from the federal excise tax imposed by Internal Revenue Code Section 4974. Securing this approval ensures that participants are not penalized for an administrative error caused by the plan.

Section IV: Revision of Administrative Procedures

Explain the internal changes you have put in place to ensure compliance going forward. For example, explain how your recordkeeping software has been configured to automatically generate annual reports of participants approaching their Required Beginning Date, or describe new procedures for auditing participant death records.

Section V: Enclosures and Attachments

Assemble and check off all supporting documentation, including the detailed spreadsheet of affected participants, dates of birth, required distribution dates, calculated RMDs, allocable earnings, and relevant plan document sections.

8. Required Documents and Information Needed Before Filling

Before preparing Form 14568-H, compile the following payroll and recordkeeping files:

Participant census data showing dates of birth, dates of hire, termination or retirement dates, and ownership percentages (to identify 5% owners).
Prior year-end account statements (the December 31 balance of the year preceding each missed RMD is required to compute the correct distribution amount).
IRS Uniform Lifetime or Single Life Expectancy tables applicable to each distribution year.
Detailed accounting spreadsheets showing individual RMD calculations, allocable investment earnings, and distribution dates.
Beneficiary designation forms and death certificates for deceased participants.
Completed master Form 14568 and Form 8950.
A signed Form 2848 (Power of Attorney) if a CPA, ERISA attorney, or pension consultant represents your organization.

9. Common Mistakes to Avoid

Errors on Form 14568-H can delay IRS approval and leave participants vulnerable to tax penalties. Be sure to avoid these frequent errors:

Forgetting to Request Section 4974 Relief: If you fail to check the box in Section III requesting the excise tax waiver, the IRS compliance statement will not protect participants from individual tax penalties.
Using the Wrong Prior-Year Account Balance: RMD calculations must be based on the account balance as of December 31 of the preceding calendar year. Using the current-year balance results in incorrect distribution amounts.
Omitting Investment Earnings: For defined contribution plans, you cannot simply pay out the flat missed RMD amount. Federal rules require you to calculate and add allocable investment earnings from the original due date to the payout date.
Altering Model Language: The wording in Form 14568-H is pre-approved by the IRS. Striking out or rewriting standard text can cause the IRS to reject the filing as a model submission.
Missing the 150-Day Implementation Window: The plan administrator must ensure that all catch-up distributions are executed and funds disbursed within 150 days of receiving the signed IRS compliance statement.

10. Penalties for Non-Filing or Errors

Ignoring missed RMDs can result in severe financial penalties for both the plan and its participants if discovered during an IRS examination:

Total Plan Disqualification: Failing to satisfy the requirements of Section 401(a)(9) is a disqualifying defect that revokes the tax-exempt status of the plan’s trust.
Participant Excise Taxes: Affected participants and beneficiaries face a federal excise tax under Section 4974 (historically 50%, and 25% under updated SECURE Act rules) on the full amount of every missed distribution.
Disallowed Employer Deductions: If the plan is disqualified, the employer may lose business tax deductions taken for plan contributions across all open tax years.
Substantial Audit CAP Sanctions: If the IRS uncovers the uncorrected distribution failures during an audit, the employer must negotiate a monetary sanction under Audit CAP, which is significantly higher than standard VCP user fees.

11. Related Forms or Schedules

Form 14568-H operates within an interconnected system of retirement plan compliance forms:

Form 14568: Model VCP Compliance Statement (the master application).
Form 14568-B: Schedule 2 – Nonamender Failures for 401(a) Plans.
Form 14568-E: Schedule 5 – Plan Loan Failures.
Form 8950: Application for Voluntary Correction Program (VCP) Submission.
Form 8951: Additional User Fee Payment for Open VCP Request.
Form 5329: Additional Taxes on Qualified Plans (Including IRAs) and Other Tax-Favored Accounts.
Form 1099-R: Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc.
Form 5500 / 5500-SF: Annual Return/Report of Employee Benefit Plan.
Form 2848: Power of Attorney and Declaration of Representative.

12. Frequently Asked Questions (FAQs)

1. What is the Required Beginning Date (RBD) for plan participants?

For most participants who do not own more than 5% of the employer, the Required Beginning Date is April 1 of the calendar year following the later of the year they reach the statutory RMD age or the year they retire. For 5% owners, RMDs must begin by April 1 following the statutory age, regardless of whether they have retired.

2. Does filing Form 14568-H automatically waive the excise tax for participants?

Yes, provided the plan sponsor explicitly requests the waiver under Section III and the IRS approves and signs the final compliance statement. This grants a collective waiver, protecting participants from the Section 4974 excise tax.

3. Do participants need to file Form 5329 if the employer resolves the issue on Form 14568-H?

No. When the IRS approves an excise tax waiver under a formal VCP compliance statement, individual participants do not need to file Form 5329 to request individual waivers for the disclosed failures.

4. How are missed RMDs adjusted for investment earnings in a 401(k) plan?

The missed distribution must be adjusted for actual investment returns earned by the participant’s account from the date the payment was originally due through the date the catch-up distribution is processed. If the account experienced net losses, the distribution may be adjusted downward accordingly.

5. Can an individual IRA owner use Form 14568-H to fix a missed RMD?

No. Form 14568-H is strictly for employer-sponsored plans. Individual IRA owners must take the missed distribution and request a waiver of the excise tax for reasonable cause directly on their personal tax return using Form 5329.

6. How much is the IRS user fee for submitting Form 14568-H?

The VCP user fee is based on the total net assets held in the retirement plan at the time of submission, typically ranging between $1,500 and $3,500, paid directly through Pay.gov.

13. Conclusion: Key Takeaways

IRS Form 14568-H is a critical compliance tool for employers sponsoring qualified retirement plans and 403(b) programs. By utilizing this standardized schedule under the Voluntary Correction Program, plan sponsors can correct missed distribution deadlines, bring accounts up to date with earnings, and protect both the plan’s qualified status and participants from severe excise taxes.

Because calculating historical minimum distributions and allocable investment earnings requires precise accounting and demographic records, plan sponsors should work closely with an experienced benefits attorney, third-party administrator, or qualified pension consultant when preparing Form 14568-H.

IRS Form 14568-H Guide: Required Minimum Distribution Rules