Approval to use plan-specific substitute mortality tables under section 430 for an aggregated group of non-union defined benefit plans (Group A)

Plain-English summary

Employers that sponsor traditional (defined benefit) pension plans must
calculate how much to fund each year, and those calculations depend on
mortality assumptions (how long retirees are expected to live). Section 430
lets a plan sponsor use its own "substitute" mortality tables, built from the
plan's actual experience, instead of the IRS standard tables, if the IRS
approves them in advance. Here, a sponsor asked to use substitute mortality
tables for an aggregated group of two non-union plans ("Group A"). The IRS reviewed
how the tables were developed (from an experience study covering 2019 through
2023, base year 2021) and approved them for up to five plan years starting
January 1, 2026, for combined male and female annuitants and non-annuitants,
excluding disabled participants (disabled participants use the standard
tables). Approval is conditioned on annual actuarial certifications that the
tables remain accurate. A companion request for the sponsor's union plans
("Group B") is handled in
a separate ruling.

Note: this document was released as a scanned image. The numeric mortality-rate
table (ages 15 to 120), the mortality-ratio and credibility-weighting-factor
table, and the population-stability table did not survive optical character
recognition and are marked [illegible] below. Their values were not
reconstructed.

Ruling snapshot

• Question: May the sponsor use plan-specific substitute mortality tables
  under section 430 for its aggregated group of non-union defined benefit plans?
• Outcome: Approved (for up to 5 plan years beginning January 1, 2026,
  subject to annual actuarial certification).
• Key authorities: IRC § 430(h)(3); ERISA § 303(h)(3); Treas. Reg. §
  1.430(h)(3)-2; Rev. Proc. 2024-32.

Full text (IRS public release)

Significant Index No. 0430.00-00

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224

TAX EXEMPT AND                       DEC 17 2025
GOVERNMENT ENTITIES
DIVISION

Release Number: 202611017
Release Date: 3/13/26

Re: Substitute Mortality Table Ruling

Taxpayer =
EIN: -

Group A - Aggregated Group of Non-Union Plans:

Plan 1 =
EIN: - ; PN:

Plan 2 =
EIN: - ; PN:

Group B - Aggregated Group of Union Plans:

Plan 3 =
EIN: - ; PN:
Plan 4 =
EIN: - ; PN:

Dear -------------:

This letter is to inform you that your request to use substitute mortality tables for making
computations under section 430 of the Internal Revenue Code ("Code") for the above Plan 3
and Plan 2 (hereinafter referred to as "Group A") has been granted with respect to the
populations specified in this letter. This ruling is effective for a period of up to 5 plan years
beginning with the plan year commencing January 1, 2026 for Group A. Your request has been
granted in accordance with section 430(h)(3) of the Code and section 303(h)(3) of the
Employee Retirement Income Security Act of 1974 ("ERISA").

This approval applies to the following specific populations of Group A:

• Male combined annuitants and non-annuitants, excluding disabled participants
• Female combined annuitants and non-annuitants, excluding disabled participants

Taxpayer also requests approval for substitute mortality tables for Plan 3 and Plan 4
(hereinafter referred to as "Group B"), which will be addressed in a separate ruling letter.

This request is made in accordance with section 430(h)(3)(C) of the Code, section 303(h)(3) of
ERISA, section 1.430(h)(3)-2 of the Treasury Regulations ("Regulations"), and Revenue
Procedure 2024-32.

Taxpayer previously received a ruling, dated February 5, 2025, granting the use of substitute
mortality tables for Group A identified above, effective for a period up to 5 years beginning with
the plan years commencing January 1, 2025. The approved use of the substitute mortality
tables currently being used will expire on December 31, 2029.

Due to the amendments to section 1.430(h)(3)-2 of the Regulations
published in the Federal Register on July 31, 2024, Taxpayer submitted this new request for a
ruling to use substitute mortality tables for Group A for a period of up to 5 plan years starting
with the plan years beginning January 1, 2026.

Section 430(h)(3)(A) of the Code states, in relevant part, that the Secretary shall by regulation
prescribe mortality tables to be used in determining any present value of making any
computation under section 430 of the Code.

Section 430(h)(3)(C) of the Code states, that upon request by the plan sponsor and approval
by the Secretary, a mortality table shall be used in determining any present value or making
any computation under section 430 of the Code during the period of consecutive plan years
(not to exceed 10) specified in the request.

Section 430(h)(3)(C)(ii) of the Code states, in relevant part, a substitute mortality table shall
cease to be in effect as of the earliest of:

(1) the date on which there is a significant change in the participants in the plan by reason
of a plan spinoff or merger or otherwise, or

(2) the date on which the plan actuary determines that such substitute mortality table does
not meet the following requirements of Section 430(h)(3)(C)(iii) of the Code.

Section 430(h)(3)(C)(iii) of the Code states, in relevant part, that a mortality table meets the
requirements of this section if:

(I) there is a sufficient number of plan participants, and the pension plans have been
maintained for a sufficient period of time, to have credible information necessary,
and

(II) such substitute mortality table reflects the actual experience of the pension plans
maintained by the sponsor and projected trends in general mortality experience.

Section 1.430(h)(3)-2(c)(3) of the Regulations states, in relevant part, that the base year for the
base substitute mortality table is the calendar year that contains the day before the midpoint of
the experience study period. Additionally, a plan's substitute mortality tables must be
generational mortality tables.

Section 1.430(h)(3)-2(c)(4) of the Regulations states, in relevant part, that if separate mortality
tables are used for certain disabled individuals as permitted under section 430(h)(3)(D) of the
Code, then those disabled individuals are disregarded for all purposes under
section 1.430(h)(3)-2 of the Regulations, and mortality experience with respect to those
individuals must be excluded in developing mortality rates for substitute mortality tables.

Section 1.430(h)(3)-2(c)(6)(ii) of the Regulations states, in relevant part, that a plan's substitute
mortality tables must not be used beginning with the earliest of:

(A) For a plan using a substitute mortality table for only one gender because of a lack of
credible mortality information with respect to the other gender, the first plan year for
which there is credible mortality information with respect to the gender that had lacked
credible mortality information (unless an approved substitute mortality table is used for
that gender),

(B) The first plan year in which the plan fails to satisfy the requirement that other plans and
populations in the controlled group must also use substitute mortality tables unless it
can be demonstrated that they do not have credible mortality information (taking into
account the transition period for newly-affiliated plans),

(C) The second plan year following the plan year for which there is a significant change in
individuals covered by the plan as described in Section 1.430(h)(3)-2(c)(6)(iii) of the
Regulations,

(D) The first plan year following the plan year for which a substitute mortality table used for
a plan population is no longer accurately predictive of future mortality of that
population, as determined by the Commissioner or as certified by the plan's actuary to
the satisfaction of the Commissioner, or

(E) The date specified in guidance published in the Internal Revenue Bulletin in
conjunction with a replacement of mortality tables specified under section 430(h)(3)(A)
of the Code and section 1.430(h)(3)-1 of the Regulations, other than annual updates to
the static mortality tables issued as noted in section 1.430(h)(3)-1(c)(1)(iv) of the
Regulations or changes to the mortality improvement rates under section 1.430(h)(3)-
1(b)(1)(iii) of the Regulations.

Section 1.430(h)(3)-2(c)(6)(iii) of the Regulations states, in relevant part, a significant change
in the individuals covered by a substitute mortality table for a plan year occurs if the number of
individuals covered by the substitute mortality table for the plan year is less than 80% or more
than 120% of either the average number of individuals in that population over the years
covered by the experience study on which the substitute mortality tables are based, or the
number of individuals covered by the substitute mortality table in a plan year for which a
certification (described below) was made on account of a prior change in coverage. However,
a change in coverage is not treated as significant if the plan's actuary certifies in writing to the
satisfaction of the Commissioner that the substitute mortality tables used for the population
continue to be accurately predictive of future mortality of that population (taking into account
the effect of the change in the population).

Section 1.430(h)(3)-2(d)(2) of the Regulations states, in relevant part, that the experience
study period must consist of 2, 3, 4, or 5 consecutive 12-month periods, and must be the same
period for all populations.[1] The last day of the experience study period must be less than 3
years before the first day of the first plan year for which the substitute mortality tables are to
apply. However, if the plan sponsor submits a request for approval to use substitute mortality
tables more than 1 year (and less than 2 years) before the first day of the first plan year for
which the substitute mortality tables are to apply, then the experience study is not treated as
failing to satisfy the rule in section 1.430(h)(3)-2(d)(2)(ii)(A) of the Regulations if the last day of
the final year reflected in the experience data is less than 2 years before the date of
submission.

Section 1.430(h)(3)-2(d)(4) of the Regulations states, in relevant part, that the base mortality
rates are determined by multiplying the mortality rate from the standard mortality table by the
mortality ratio (modified for ages 96 and older). If the simplified rule under section 1.430(h)(3)-
2(c)(2)(ii)(B) of the Regulations is used for the population, then the mortality ratio is determined
only taking into account people who are at least 50 years old and less than 100 years old, but
the mortality ratio is applied to all ages.

Section 1.430(h)(3)-2(d)(4)(iii)(B) of the Regulations require that adjustments be made to the
standard mortality table for any 12-month period in the experience study that begins after
December 31, 2019 and before January 1, 2023. Such adjustment factors are 15% increases
for calendar years 2020 and 2021 and a 7.5% increase for calendar year 2022.

Section 1.430(h)(3)-2(e)(1) of the Regulations states, in relevant part, that if the actual number
of deaths is at least equal to 100 and is less than the full credibility threshold, then the base
mortality rates are determined using a partial credibility weighting factor as calculated under
section 1.430(h)(3)-2(e)(2).

The substitute mortality tables were developed based on an experience study period from
January 1, 2019 through December 31, 2023, with a base year of 2021. This satisfies the
requirements under sections 1.430(h)(3)-2(c)(3) and (d)(2) of the Regulations.

The substitute mortality tables were developed by adjusting the applicable standard mortality
tables in section 1.430(h)(3)-1(d) of the Regulations with the mortality ratio and credibility
weighting factors shown below.

[1] If two or more plans are aggregated and not all of the plans have the same plan year, then the experience study
period may be a period that is not a multiple of 12 months provided that four criteria under section 1.430(h)(3)-
2(c)(5)(ii) are met.

Mortality Ratio and Credibility Weighting Factor Table

[illegible - numeric table did not survive scanning; column for combined male
and female annuitants and non-annuitants, excluding disabled participants;
rows for Mortality Ratio and Credibility Weighting Factor]

These were determined by combining male annuitant, female annuitant, male non-annuitant,
and female non-annuitant (excluding disabled participants) experience.

This approval applies to the following specific populations:

• Male and female combined annuitants and non-annuitants, excluding disabled
participants

Disabled participants will use the standard mortality tables in accordance with section
430(h)(3)(D) of the Code and section 1.430(h)(3)-2(c)(4) of the Regulations.

Based on the information provided by Taxpayer, there are no populations that lack credible
mortality experience. Therefore, there are no populations for which the standard mortality
tables will be used for calculations under section 430 of the Code.

In granting this approval, we have only considered whether the substitute mortality rates were
developed in accordance with section 1.430(h)(3)-2 of the Regulations and Revenue
Procedure 2024-32. Accordingly, we are not expressing any opinion as to the accuracy or
acceptability of any calculations or other material submitted with your request.

Permission is hereby granted to use the substitute mortality rates shown in the table below for
Group A.

Substitute Mortality Tables
Approved for use beginning with the plan years commencing
January 1, 2026 for Group A

Base year 2021

[illegible - the substitute mortality rate table (columns: Male Annuitants
and Non-annuitants excluding disabled participants; Female Annuitants and
Non-annuitants excluding disabled participants; rows: Age 15 through Age 120)
did not survive scanning. The age labels are legible but the numeric mortality
rates are blank in the scanned release.]

The above mortality rates were developed based on an experience study period from January
1, 2019 through December 31, 2023, with a base year of 2021.

The Internal Revenue Service ("IRS") has reviewed the substitute mortality rates and
supporting information, and has determined that based on the information submitted, the rates
were developed in accordance with section 1.430(h)(3)-2 of the Regulations and Revenue
Procedure 2024-32.

The above rates must be applied on a generational basis, as provided in section 1.430(h)(3)-
2(c)(3)(i) of the Regulations.

Your attention is called to section 430(h)(3)(C)(ii) of the Code and
section 1.430(h)(3)-2(c)(6)(ii) of the Regulations, which describe the circumstances in which
the use of the substitute mortality table will terminate before the end of the 5-year period
described above. In general, the substitute mortality tables can no longer be used as of the
earliest of:

(1) For a plan using a substitute mortality table for only one gender because of a lack of
credible mortality information with respect to the other gender, the first plan year for
which there is credible mortality information with respect to the gender that had lacked
credible mortality information (unless an approved substitute mortality table is used for
that gender),

(2) The first plan year in which the plan fails to satisfy the requirements of
section 1.430(h)(3)-2(c)(1) of the Regulations, regarding the requirement that other
plans and populations in the controlled group must also use substitute mortality tables
unless it can be demonstrated that they do not have credible mortality information
(taking into account the transition period for newly-affiliated plans in section
1.430(h)(3)-2(f)(3) of the Regulations),

(3) The second plan year following the plan year for which there is a significant change in
individuals covered by the plan as described in section 1.430(h)(3)-2(c)(6)(iii) of the
Regulations,

(4) The first plan year following the plan year for which a substitute mortality table used for
a plan population is no longer accurately predictive of future mortality of that
population, as determined by the Commissioner or as certified by the plan's actuary to
the satisfaction of the Commissioner, or

(5) The date specified in guidance published in the Internal Revenue Bulletin in
conjunction with a replacement of mortality tables specified under section 430(h)(3)(A)
of the Code and section 1.430(h)(3)-1 of the Regulations, other than annual updates to
the static mortality tables issued as noted in section 1.430(h)(3)-1(c)(1)(iv) of the
Regulations or changes to the mortality improvement rates under section 1.430(h)(3)-
1(b)(1)(iii) of the Regulations.

Section 1.430(h)(3)-2(c)(6)(iii) of the Regulations provides that the use of substitute mortality
tables must be discontinued after a significant change in coverage unless the plan's actuary
certifies in writing to the satisfaction of the Commissioner that the substitute mortality tables
used for the population continue to be accurately predictive of future mortality of the population
(taking into account the effect of the change in the population). As noted on page 4 of this
letter, a significant change in coverage occurs if the number of individuals covered by the
substitute mortality table for a plan year is less than 80 percent or more than 120 percent of
either (1) the average number of individuals in that population over the years covered by the
experience study on which the substitute mortality table is based, or (2) the number of
individuals covered by the substitute mortality table in a plan year for which a certification
described in section 1.430(h)(3)-2(c)(6)(iii)(A) of the Regulations was made.

The following information was submitted by Taxpayer to demonstrate stability:

[illegible - stability table did not survive scanning; columns: Average Number
During Experience Study Period, Number as of 12/31/2024, Percentage
Difference; row: Combined male and female annuitants and non-annuitants]

A certification must be provided each year that it is required under the Regulations, as
described above, signed by the enrolled actuary for the plan and stating that the substitute
mortality tables continue to be accurately predictive of the expected future mortality for the
plan. The certification must also contain a statement that:

a. The enrolled actuary is current with educational requirements set forth by the Joint
Board for the Enrollment of Actuaries as well as any other actuarial designations
asserted;

b. The enrolled actuary was personally involved in the determination that the
substitute mortality table is still accurately predictive and provides the actuary's best
estimate for the Plan;

c. In determining that the substitute mortality table is still accurately predictive, the
enrolled actuary took into consideration the effect of business combinations, plan
mergers or spinoffs and settlements/other risk transfers, and other events that
would have similar effects on the relevant populations; and,

d. The enrolled actuary has the specific knowledge and experience to make the
judgements set forth above and attests to these representations.

All required certifications must be provided on or before the date the Form 5500 is filed for
each plan year for which the certification is required and must be accompanied by the
supporting information relied upon by the enrolled actuary to make that certification. To the
extent possible, please also provide the following supporting information:

(1) The number of actual deaths during the experience study period used to develop the
substitute mortality tables and the beginning and ending dates of the experience study
period.

(2) A table showing the number of expected deaths and actual deaths, reported separately
as of December 31, 2024 and for each plan year beginning with deaths during the plan
year ending December 31, 2024 through the plan year immediately preceding the most
recent actuarial valuation, and in total.

(3) A table similar to the stability demonstration required under section 8.1 of Revenue
Procedure 2024-32, showing the average number of participants in the population
covered by the substitute mortality table during the experience study period and the
number of participants in that population as of the end of each plan year, beginning with
December 31, 2024 through the plan year immediately preceding the most recent
actuarial valuation, expressed both as a headcount and as a percentage of the average
number of participants in the experience study.

(4) A table showing a comparison of (i) the average ages and (ii) percentage of the
population, by the following monthly single life annuity brackets: under $100, between
$100 and $250, between $250 to $500, between $500 to $1,000, between $1,000 and
$1,500, and $1,500 and over, along with the average age and average benefit amount
for the population in total. This information should also be provided for the population in
the experience study and at the end of each plan year, beginning with the valuation date
for the first plan year that the certification is required, through the date immediately
preceding the most recent actuarial valuation at the time the information is reported.

(5) An explanation of any material changes in the population.

This information must be provided to David M. Ziegler (or to another individual designated by
the Service) to the following address:

Internal Revenue Service
Attn: Mr. David M. Ziegler
TE/GE: SE:T:EP:RA:T:A2
IR-6213
1111 Constitution Ave. NW
Washington DC 20224-0002

Failure to provide this information by the due date may result in a requirement that the
standard mortality tables must be used for purposes of section 430 of the Code, beginning with
the earlier of (1) the plan year for which the deadline for providing this information is missed or
(2) the date required for early termination of the use of the substitute mortality tables pursuant
to section 1.430(h)(3)-2(c)(6)(ii) of the Regulations.

This ruling is directed only to the taxpayer that requested it. Section 6110(k)(3) of the Code
provides that it may not be used or cited by others as precedent.

When filing Form 5500 for the plan years for which the substitute mortality tables are used,
please note the information that is required to be attached to Schedule SB (Actuarial
Information) in accordance with the instructions to that form.

This letter ruling may be revoked or modified retroactively if there was a misstatement or
omission of controlling facts, the facts at the time of the transaction are materially different from
the controlling facts on which the letter ruling was based, or the transaction involves a
continuing action or series of actions and the controlling facts change during the course of the
transaction.

Pursuant to a Power of Attorney and Declaration of Representative (Form 2848) on file with
this office, a copy of this letter ruling is being sent to your authorized representatives.
Additionally, a copy of this letter ruling is being sent to the Manager, Classification Group 4 in
Houston, Texas.

If you require further assistance in this matter, please contact (ID# )
at ( ) -

Sincerely,

David M. Ziegler, Manager
Employee Plans Actuarial Group 2

Enclosures
Notice 437, Notice of Intention to Disclose (Rulings)
A deleted copy of the ruling

cc: