Rev. Proc. 2026-30, August 5, 2026.

On September 4, 2026, a significant shift in tax administration takes effect for practitioners representing qualified retirement plans and tax-exempt organizations. The Internal Revenue Service (IRS) has issued Revenue Procedure 2026-30, which establishes that all requests for letter rulings and nonbank trustee approval letters under the jurisdiction of the Employee Plans Rulings and Agreements Office must be submitted electronically. Specifically, this procedure mandates the use of Form 15662, Application for Private Letter Rulings, and requires that all submissions and associated user fees be processed through the Pay.gov website. Mailed or hand-delivered paper submissions, along with physical paper checks, will no longer be accepted and will be returned to the applicant. This article analyzes the background, legal authority, and section-by-section modifications enacted by this new procedure, providing a technical roadmap for tax professionals.

Background and the Facts of the Procedure

Under the existing administrative framework, Revenue Procedure 2026-4 provides the annual general instructions for requesting letter rulings and determination letters from the Employee Plans Rulings and Agreements Office. Although the IRS released Form 15662 in 2025 to “simplify and standardize the submission process,” the use of this form was not previously mandatory, nor did Revenue Procedure 2026-4 provide a mechanism for electronic user fee payments through Pay.gov for letter rulings. Consequently, tax professionals historically complied with a paper-intensive process. Revenue Procedure 2026-4 generally required taxpayers to “mail or hand deliver requests for Letter Rulings to a specified address along with a paper check for the applicable user fee”. Revenue Procedure 2026-30 alters this factual landscape by integrating all Employee Plans letter rulings and nonbank trustee approval letters (collectively, “Letter Rulings”) into a single, mandatory digital pipeline.

The Modernization Imperative: Reasons for Issuing the Procedure

The IRS’s decision to issue Revenue Procedure 2026-30 is rooted in a broader administrative objective to modernize tax practice and reduce processing backlogs. The IRS issued Form 15662 in 2025 “to simplify and standardize the submission process for Letter Rulings”. However, without an electronic filing mandate, the system remained fragmented, and the IRS continued to incur significant overhead handling paper documents and physical checks. By transitionally mandating an electronic submission process on the Pay.gov website on or after September 4, 2026, the IRS aims to align Employee Plans letter rulings with other programs that are already fully electronic. For example, determination letter requests on the Form 5300 series, pre-approved plan opinion letters, and Voluntary Correction Program (VCP) submissions under the Employee Plans Compliance Resolution System (EPCRS) are already restricted to electronic submissions on Pay.gov. Requiring electronic submission for letter rulings and nonbank trustee approval letters represents the final phase of eliminating paper-based intake within this division, thereby enhancing speed, security, and tracking.

Statutory Authority and Analysis of the Law

The administrative power of the IRS to impose user fees and regulate the filing of ruling requests is derived from federal statute. Section 7528 of the Internal Revenue Code of 1986, as amended, “directs the Secretary or a delegate to establish a program requiring the payment of user fees for requests to Employee Plans Rulings and Agreements for letter rulings, opinion letters, determination letters, and similar requests”. Under I.R.C. § 7528(b)(1), these fees must vary according to categories and subcategories, and must be “determined after considering the average time for, and difficulty of, complying with requests in each category and subcategory”. The jurisdiction of the Employee Plans Rulings and Agreements Office over letter rulings is established under Revenue Procedure 2026-4, which provides that letter rulings are issued on specific matters “if appropriate in the interest of sound tax administration”. By modifying the procedural regulations of Revenue Procedure 2026-4, the IRS is exercising its statutory delegation to prescribe the manner and method of both paying these user fees and submitting the underlying requests. Furthermore, Form 15662 carries administrative force as an information collection approved by the Office of Management and Budget (OMB) under control number 1545-1520.

Application of the Law to the Filing Process

The statutory authority under I.R.C. § 7528 is applied to the facts by Revenue Procedure 2026-30's complete replacement of the physical mailing and check-payment systems. Effective September 4, 2026, the pay.gov electronic portal becomes the exclusive venue for submissions and payments. The procedural application of this rule is uncompromising: “Requests for letter rulings and nonbank trustee approval letters must be submitted on www.pay.gov and may not be mailed to the Service”. Tax practitioners must apply the new filing standards defensively. Under the updated regulations, “If a paper submission is mailed, the submission will be returned to the applicant, including any submitted paper checks”. This means that physical checks are no longer accepted under any circumstances. The IRS has integrated Form 15662 directly into Pay.gov, which means that the form, the supporting documentation required by Revenue Procedure 2026-4, and the electronic payment of the user fee must be bundled into a single electronic upload.

Technical Modifications to Revenue Procedure 2026-4

To implement this electronic mandate, Section 3 of Revenue Procedure 2026-30 enacts eleven specific, technical modifications to the text of Revenue Procedure 2026-4. Tax professionals must carefully update their reference materials to reflect these precise textual changes:

First, the third paragraph of Section 6.03(3) of Revenue Procedure 2026-4, which governs the timing of user fees for expedited handling, is modified to state: “A request for expedited handling of a request for a letter ruling will not be forwarded to the appropriate group for action until the user fee, in the correct amount, is received”. This accounts for the shift away from physical check verification.

Second, Section 27.08 of Revenue Procedure 2026-4 is modified to ensure that additional information requested by an IRS representative during the review process can be submitted securely and electronically: “Additional information can be sent by fax, Taxpayer Digital Communications Secure Messaging, the IRS Document Upload Tool, or to the address provided by the Service representative who requested the information”.

Third, Section 30.07(4) of Revenue Procedure 2026-4, which formerly described physical check payments, is deleted in its entirety and replaced with a strict electronic mandate: “Payment of user fees for letter ruling and nonbank trustee approval letter requests. User fees for letter ruling and nonbank trustee approval letter requests must be paid using www.pay.gov. The Service no longer accepts checks for letter ruling and nonbank trustee approval letter submissions”.

Fourth, Section 30.08 of Revenue Procedure 2026-4 is modified to insert a new paragraph (3), cementing the mandatory form requirement: “Letter ruling and nonbank trustee approval letter requests must be made to the Service on www.pay.gov using Form 15662, Application for Private Letter Rulings”.

Fifth, the general filing routing rules are updated. The first sentence of Section 31.01 of Revenue Procedure 2026-4 is modified to read: “Requests should be submitted in the manner prescribed in section 31.01(1), mailed to the address provided in section 31.01(2), or mailed or hand delivered to the appropriate address provided in section 31.01(3)”.

Sixth, Section 31.01(1) of Revenue Procedure 2026-4 is modified to remove the Covington, Kentucky address for mailing letter ruling requests, replacing it with the electronic mandate and redirecting fee reconsideration requests: “Requests for letter rulings and nonbank trustee approval letters must be submitted on www.pay.gov and may not be mailed to the Service. If a paper submission is mailed, the submission will be returned to the applicant, including any submitted paper checks. Requests for reconsideration of user fees under section 30.11 for letter rulings and nonbank trustee approval letters should be mailed to: Internal Revenue Service, Attention: EP Letter Rulings, SE:T:EP:RA:T:A2, IR-6213, 1111 Constitution Avenue, NW, Washington, DC 20224-0002”.

Seventh, Section 31.01(3) of Revenue Procedure 2026-4 is modified to update the delivery address for Express Mail or courier shipments of pre-approved plan opinion letters (which are still paper-eligible in limited mass-submitter contexts): “Requests for employee plans opinion letters described in section 31.01(2) of this revenue procedure that are shipped by Express Mail or a delivery service should be sent to: Internal Revenue Service, Attention: EP Opinion Letters, TE/GE Stop 31A Team 105, 7940 Kentucky Drive, Florence, KY 41042”. Additionally, hand-delivered requests must be marked “OPINION LETTER SUBMISSION” and delivered to the Florence, Kentucky courier desk.

Eighth, Appendix D of Revenue Procedure 2026-4, which contains the sample format for a letter ruling request, is modified to delete the obsolete Covington, Kentucky physical address: “P.O. Box 12192, TE/GE Stop 31A Team 105, Covington, KY 41012-0192”.

Ninth, Section F.2.c on the second page of Appendix D is modified to align the procedural checklist with Pay.gov: “The required user fee has been paid through pay.gov. [See section 6.02(15).]”.

Tenth, the first paragraph of Appendix E of Revenue Procedure 2026-4, which contains the user checklist, is modified to state: “The Service will be able to respond more quickly to your letter ruling request if it is carefully prepared and complete. To ensure that your request is in order, use this checklist. Complete the four items of information requested before the checklist. Answer each question by circling ‘Yes,’ ‘No,’ or ’N/A.’ If a question contains a place for a page number, insert the page number (or numbers) of the request that gives the information called for by a yes answer to a question. Sign and date the checklist (as taxpayer or authorized representative) and attach it as the first document of your request”.

Eleventh, Question 23 of the Appendix E checklist is updated to read: “Have you included the correct user fee with the request? See section 6.02(15) and section 30 and Appendix A for the correct amount and additional information on user fees”.

Administrative Compliance and Drafting Information

From an administrative standpoint, Revenue Procedure 2026-30 does not change the substantive information collected under the private letter ruling program, but merely the electronic method of delivery. Accordingly, the IRS notes that the procedure “requires Form 15662 to be used and requires it to be submitted electronically but does not change the information collected by Form 15662. Therefore, this revenue procedure does not change the existing OMB approval for control number 1545-1520”.

The drafting credits for these guidance documents reflect the technical coordination behind their release. The principal author of Revenue Procedure 2026-30 is Jordan D. Kohl of the Office of the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes). For practitioners needing direct administrative clarification, the IRS has designated the Employee Plans office contact at (202) 317-5984. By comparison, the principal author of the baseline annual guide, Revenue Procedure 2026-4, was Isaac Stein, with Ada Perry designated as the primary contact.

Technical Conclusions and Actionable Guidance

Revenue Procedure 2026-30 officially modifies Revenue Procedure 2026-4. By establishing an effective date of September 4, 2026, the IRS has provided a very brief transition window for practitioners to adapt. The technical conclusions are clear:

Paper filings and physical checks are completely obsolete for Employee Plans letter ruling and nonbank trustee approval letter requests after September 3, 2026.
Form 15662 is now a mandatory single, standardized form that must be fully executed and submitted through Pay.gov.
Procedural checklists, power of attorney forms (Form 2848), and deletions statements under I.R.C. § 6110 must be bundled as electronic attachments to the Pay.gov submission.

To avoid the administrative setback of having a request returned unprocessed, tax professionals must immediately integrate Form 15662 and Pay.gov registration into their standard Employee Plans ruling workflows.

Prepared with assistance from Gemini Notebook.