Missed the 60-Day IRA Rollover Deadline? A New IRS Correction Program Is Coming in 2027

Moving retirement money between accounts is supposed to be routine, until a 60-day clock runs out. On Oct. 22, 2026, the IRS issued Revenue Procedure 2026-33, which sets up a new correction program for certain individual retirement account (IRA) mistakes, including missed rollover deadlines. The program does not take effect until May 1, 2027, and some details remain open for comment.

The 60-day rule in plain terms

When you take a distribution from an IRA or workplace plan and want to roll it into another retirement account, you generally have 60 days from receiving the money to complete the rollover.

If you miss the window:

• The amount is generally taxable, unless it was already taxed or is a qualified Roth distribution.
• The 10% additional tax on early distributions may apply unless an exception covers it.
• The IRS can waive the deadline when circumstances were beyond a person's control.

What Rev. Proc. 2026-33 adds

The procedure creates the IRA Compliance Resolution System (ICRS). At launch it has one component, the IRA Voluntary Correction Program, modeled on the correction program long used for employer retirement plans. According to the procedure and summaries by KPMG, it covers several kinds of IRA errors:

• Required minimum distribution failures
• IRA establishment failures
• Distributions or rollovers by nonspouse beneficiaries
• Missed 60-day rollovers

It excludes egregious failures, diversion or misuse of IRA assets, and abusive tax avoidance transactions. For 60-day rollover problems, the applicant must be the IRA owner, and the program is generally unavailable while the owner's income tax return is under examination (an IRS audit).

How it fits with the existing routes

Today, a person who needs a formal waiver generally requests a private letter ruling (PLR), the IRS's individualized written guidance. The procedure says that in 2027 a waiver request may be made through ICRS or through the annual PLR procedure. It also says it is anticipated that from 2028 such requests will only be permitted under ICRS.

"Anticipated" matters here. The 2027 annual procedure for ruling requests (Rev. Proc. 2027-4) had not yet been published, and the IRS has invited comments through Jan. 20, 2027, so the final shape could change.

Two existing routes are not going away:

• Automatic waivers. Certain automatic waivers remain available.
• Self-certification. A person gives the receiving custodian (the bank or brokerage holding the account) a signed letter stating a qualifying reason for the delay. It involves no IRS fee and no IRS filing, but it is not an IRS ruling, and an audit can still deny it.

Institutions are also not required to accept late rollovers. ICRS submissions carry a user fee set out in the procedure, so check the fee schedule before comparing options.

What a waiver does not fix

The IRS has said it cannot waive the rule that limits IRA-to-IRA rollovers to one per year, so a waiver does not solve every rollover problem. A direct trustee-to-trustee transfer, where the money moves between institutions without passing through the account owner, sidesteps the 60-day clock entirely, which is why many people use it for rollovers.

Open questions

Several practical points were not clear in the sources reviewed:

• How the IRS will apply its "equity or good conscience" standard in practice
• How broadly "under examination" is defined
• How long processing will take
• Whether custodians must honor an ICRS-approved late rollover

Anyone with a real rollover problem should consider talking with a tax professional or the account custodian rather than relying on a summary.

This article is educational commentary on public tax guidance, not personalized investment, trading, or tax advice.