What are the IRS required minimum distribution (RMD) rule changes taking effect for 2026?
Executive summary
The IRS has announced it will not make certain proposed RMD (required minimum distribution) regulations applicable until the 2026 distribution calendar year, effectively delaying rules that had been expected to start in 2025 and giving plans, recordkeepers and taxpayers more time to implement changes (IRS Announcement 2025‑2 summarized by several firm write‑ups) [1] [2] [3]. The delayed provisions specifically affect amendments to Regulations §§1.401(a)[4]‑4, ‑5 and ‑6 — including spousal election rules for defined contribution plans, treatment of Roth/designated Roths, 10‑year/inherited account rules, and certain QLAC and corrective‑distribution procedures — and taxpayers are directed to use reasonable, good‑faith interpretations before the 2026 applicability date [5] [6].
1. What the IRS actually delayed — the technical rule set
The agencies stated the provisions anticipated in the July 2024 proposed regulations that amend §§1.401(a)[4]‑4, 1.401(a)[4]‑5 and 1.401(a)[4]‑6 will not apply earlier than the 2026 distribution calendar year, moving the earliest effective date from 2025 to 2026 for those proposed changes [2] [5]. Multiple industry summaries list the same three regulation sections as the ones covered by the Announcement and say the IRS asks stakeholders to follow reasonable, good‑faith statutory interpretations until the new applicability date [1] [5] [6].
2. The practical changes those regulations seek to clarify
The proposed regulatory package (from July 2024 and earlier proposals) was intended to implement SECURE Act and SECURE 2.0 changes such as updated treatment of surviving spouses (allowing a surviving spouse to elect to be treated as the deceased for RMD purposes in some plans), clarifications on QLACs (qualified longevity annuity contracts) and exceptions to QDRO rules, and detailed rules about how the 10‑year rule and life‑expectancy tables apply to beneficiaries and plan types [1] [6] [7]. Industry write‑ups indicate these are among the key items that sponsors and recordkeepers needed time to implement [2] [8].
3. Why the IRS delayed — implementation and industry concerns
Plan sponsors, recordkeepers and commenters warned the IRS that many of the proposed changes were operationally complex and could not be implemented effectively if the applicability date began in 2025. The IRS responded by issuing Announcement 2025‑2 to push the earliest applicability to January 1, 2026, explicitly to give stakeholders time to finalize systems and processes [2] [3] [8]. Commenters had specifically raised timing and practicality concerns, and regulators acknowledged those concerns in delaying the date [3] [5].
4. What taxpayers and plan sponsors should do now
For distribution calendar years before the final applicability date, the Treasury and IRS say taxpayers should apply a reasonable, good‑faith interpretation of the statutory provisions underlying the amendments — in short, act consistently with the law as you understand it and document that intent — while awaiting the final rules and their 2026 applicability [1] [5]. Industry advisers urge sponsors and recordkeepers to use the extra year to update plan documents, communication, systems and beneficiary procedures [2] [8].
5. Which RMD timing basics remain unchanged
Basic RMD timing mechanics — that account owners generally must take RMDs by December 31 each year (with a possible delay of the first RMD to April 1 of the following year) and that Roth IRAs are not subject to owner‑lifetime RMDs while beneficiaries remain subject to distribution rules — remain described in IRS guidance and not superseded by the applicability delay [9] [7]. Media and adviser pieces still remind retirees turning 73 in 2025 that they may delay their first distribution until April 1, 2026 (with tax consequences for taking two distributions in one calendar year), consistent with existing IRS guidance [10] [11] [12].
6. Areas of uncertainty and watch‑outs
Available sources do not provide the final text of any delayed provisions as binding for 2026 until the final regulations are issued and a formal effective date is confirmed; instead, the Announcement signals an anticipated applicability date and instructs reasonable, good‑faith interpretation in the interim [5] [6]. That means operational details — e.g., precise spousal‑election mechanics in DC plans, how QLAC exceptions will be administered, and any corrective distribution mechanics or excise‑tax tweaks — could still shift before the rules become final [6] [8].
7. Competing perspectives and implicit agendas
Regulators frame the delay as pragmatic (to allow implementation time), while industry groups emphasize that the delay reduces compliance risk and operational burden — a viewpoint that reflects recordkeepers’ and plan sponsors’ incentives to avoid costly system changes [2] [8]. Consumer‑facing advisers and outlets underscore what individual retirees must do now (RMD timing choices, Roth distinctions), which aligns with their client‑education roles but can also encourage behavior (e.g., taking RMDs earlier) that benefits bookkeeping simplicity [10] [11] [12].
Bottom line: expect the detailed SECURE‑related RMD clarifications to land with a 2026 applicability for the three cited regulation sections; meanwhile use documented, reasonable good‑faith interpretations and prepare plans, systems and communications during 2025 [5] [2].