What are the effective dates for the 2026 RMD changes and transitional rules?
Executive summary
The IRS announced that certain proposed RMD regulation changes tied to SECURE 2.0 will not apply earlier than the 2026 distribution calendar year (i.e., January 1, 2026), delaying portions of the July 2024 proposals that had been expected to be effective in 2025 [1] [2]. Meanwhile, routine RMD timing rules (first-RMD-by-April 1 following the year you reach the applicable age; subsequent RMDs by December 31) continue to apply for individuals turning 73 in 2025, meaning those people can take a first RMD as late as April 1, 2026 [3] [4].
1. IRS pushes parts of the new RMD rules into 2026 — what changed and why
The Treasury and IRS issued Announcement 2025-2 in response to industry concerns that certain proposed regulatory provisions could not be implemented in time; they stated that amendments to §§1.401(a)-4, -5 and -6 that were in the 2024 proposed RMD regulations are anticipated to apply no earlier than the 2026 distribution calendar year — effectively moving key proposed effective dates from January 1, 2025 to January 1, 2026 [1] [5] [2]. Multiple advisory firms and trade press reported that the delay covers only “some — but not all” of the proposed provisions and was intended to give plan sponsors, recordkeepers and software vendors more time to prepare [2] [6].
2. Distinction between “final regulations” already effective and “proposed” pieces postponed
The IRS had finalized a set of RMD regulations in 2024 tied to SECURE 1.0 and SECURE 2.0 changes; compliance with those final rules was generally required beginning January 1, 2025, with plan amendments due later (for most plans, December 31, 2026) [7]. The December 2024/January 2025 announcement delays only certain portions of the 2024 proposed regulations (the ones amending the three cited sections) until the 2026 distribution calendar year; it does not alter the applicability of all final regulations that already took effect for 2025 where those final rules apply [7] [1].
3. Practical deadline implications for plan sponsors and recordkeepers
Even though some regulatory provisions were delayed to January 1, 2026, regulators and commentators warned that plan amendment deadlines were not uniformly extended: model amendment work and many plan changes remain on the 2026 amendment-calendar timeline for most plans [7]. Advisers framed the IRS action as relief that “gives plan/IRA sponsors and recordkeepers some much‑needed time” to finalize technical and systems work while preserving the need to conform plan documents by the existing plan-amendment deadlines [5] [7].
4. What this means for individuals turning 73 in 2025 (RMD timing unchanged)
Separately from the regulatory-delay story, the standard RMD timing rules continue to govern individuals’ withdrawal deadlines: if you turn 73 in 2025 you must begin taking RMDs and may delay your first required distribution until April 1, 2026 — but you must still take the 2026 calendar‑year RMD by December 31, 2026 (examples and guidance are given by Charles Schwab, Nasdaq and other advisors) [3] [4] [8]. IRS materials and mainstream advisers reiterate that pushing the first distribution into the following April creates a year with two RMDs and potential tax consequences [3] [9].
5. Which proposed provisions were specifically cited as delayed
Sources name the three regulatory sections affected: 1.401(a)-4, -5 and -6, which cover various SECURE 2.0–related changes including rules around beneficiary treatment and certain plan‑level calculations; industry summaries state those amendments are anticipated to apply beginning in the 2026 distribution year [5] [1] [2]. Publications caution that the delay applies only to the “relatively few rules changes” in the proposed regulations and not the many provisions already finalized [10] [2].
6. Competing perspectives and remaining uncertainties
Industry groups and advisers welcomed the extra time to implement complex systems and communications changes [5] [6]. At the same time, sources note that taxpayers must apply a “reasonable, good‑faith interpretation” of statutory provisions for periods before the new amendments’ applicability date — a standard that creates practical uncertainty for plan administrators and individuals until final regulations are issued or clarified [1]. Publications explicitly note that not all implementation questions are resolved by the announcement and that some proposed valuation methodologies and other technical items may still have different effective dates or require further guidance [2].
7. Bottom line and what to watch next
Expect the core timing of distribution obligations for individuals (first RMD deadline April 1 following the year you hit the RMD age; subsequent RMDs by December 31) to remain in force for 2025/2026 cohorts [3] [4]. For regulatory changes that originated in the July 2024 proposals, monitor Treasury/IRS final regulations and administrative guidance for actions that the agencies said will “apply no earlier than the 2026 distribution calendar year” [1] [5]. Available sources do not mention the precise list of every single provision retained for 2025 versus deferred beyond what’s cited above; follow IRS releases and plan‑sponsor advisories for line‑by‑line clarification [7] [2].