How will IRS guidance and IRS publications update withholding and reporting for 2026 RMD changes?
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Executive summary
The IRS has pushed the applicability date for certain SECURE Act–related RMD regulations from the 2025 distribution year to no earlier than the 2026 distribution year, giving plan sponsors and recordkeepers more time to implement changes and instructing taxpayers to use reasonable, good‑faith interpretations until then [1] [2] [3]. Key published guidance and industry commentary say the delay affects portions of proposed regs under sections 1.401(a)-4, -5 and -6 and that taxpayers who rely on the delay should expect additional, formal IRS guidance before 2026 [2] [4].
1. IRS delays changeover — what was announced and why
The Treasury and IRS announced an extension of the anticipated effective date for certain proposed RMD regulations so that “certain portions” of future final regulations will apply no earlier than the 2026 distribution calendar year; the move responds to industry comments that implementation for a 2025 start was impractical for plan/IRA sponsors and recordkeepers [1] [5] [3]. Groom Law Group and Grant Thornton both note IRS Announcement 2025‑2 or related IRS signals confirm the one‑year deferral to January 1, 2026 for several named regulatory sections [2] [1].
2. Which regulatory pieces are explicitly affected
Available reporting identifies proposed regulations expected to be delayed until 2026 that relate to sections 1.401(a)-4, -5 and -6 — covering aspects of RMD calculations and qualified longevity annuity contracts (QLACs) among other SECURE 1.0/2.0 updates — though the IRS has said the delay applies to “certain portions” rather than every line in the 2024 proposals [2] [4]. Mercer and Tax Notes describe the same selective postponement: some provisions are deferred, some will be effective earlier or remain unaffected [5] [4].
3. What taxpayers and recordkeepers should do now
For periods before the final applicability date, the IRS directs taxpayers to apply a “reasonable, good‑faith interpretation” of the statutory provisions underlying the amendments — effectively instructing reliance on a practical approach until final regs are binding [1] [3]. Industry advisories emphasize that sponsors and recordkeepers should use the extra year to finalize system changes, but taxpayers should still calculate 2026 RMD amounts using year‑end balances and IRS life‑expectancy factors as usual unless and until the IRS issues contrary final rules [6] [7].
4. How withholding and reporting processes are likely to be affected
Available sources do not detail specific IRS withholding or 1099/1099‑R reporting instruction changes tied to the delayed regulations. The commentary focuses on operational implementation time for recordkeepers and plan administrators rather than step‑by‑step withholding or form changes [5] [3]. Taxpayers should therefore expect current withholding/reporting frameworks to remain in place for calculating and reporting RMDs until the IRS issues explicit guidance.
5. Timing and practical milestones to watch
Industry pieces and IRS summaries point to January 1, 2026 as the earliest applicability date for the deferred provisions and note that final regulations were published in part in July 2024 with related proposed regs from 2022 — but the IRS has signaled additional proposal/final rule activity is forthcoming before 2026 [4] [1]. Watch for formal IRS releases, updated Publications (such as Publication 590‑B) and specific plan/recordkeeper implementation notices between now and the 2026 distribution year [1] [3].
6. Penalties, RMD timing and taxpayer risk if rules change
Existing IRS guidance on deadlines, penalty relief and RMD computation remains in circulation: RMD amounts are generally based on year‑end balances and life‑expectancy tables, first RMDs may be delayed to April 1 for the initial year, and missed‑RMD excise taxes and corrective distribution procedures remain relevant [6] [8] [9]. Sources note that the IRS reduced some excise taxes under SECURE 2.0 and retains processes for corrective distributions, but the delayed regs may change the treatment of corrective distributions for certain plan types — Mercer flagged that one corrective‑distribution rule’s effective date was not delayed for IRAs while the employer‑plan provision was [5].
7. Competing perspectives and hidden agendas
Plan administrators and recordkeepers publicly welcomed the delay as necessary to avoid operational disruption; their advocacy likely influenced the IRS decision and explains industry‑focused coverage emphasizing implementation timelines rather than taxpayer confusion [2] [3]. Taxpayer‑facing outlets concentrate on the practical need to compute RMDs from year‑end balances and avoid penalties, reflecting an agenda to limit consumer tax risk rather than evaluate regulatory design [6] [8].
Limitations and next steps: reporting here is limited to the provided sources; the IRS has not yet published a detailed, final set of revised withholding or reporting instructions tied explicitly to the delayed provisions, and available sources do not mention precise changes to Forms 1099‑R, withholding tables or Publication updates (not found in current reporting). Monitor official IRS announcements and Publication 590‑B updates; employers and recordkeepers should plan system testing now to be ready for any technical changes that final regulations may require before the 2026 distribution year [1] [2] [3].