How do the SECURE Act changes and recent IRS guidance affect RMD start age and recalculation of RMDs for 2026?
Executive summary
SECURE 2.0 raised the RMD beginning age to 73 for people who reach age 72 after Dec. 31, 2022 (and to 75 for those reaching 74 after 2032), so most people who turn 73 in 2025 must start RMDs for the 2025 tax year (first payment possibly due April 1, 2026) [1] [2]. The IRS has delayed the effective date for some proposed RMD regulations until the 2026 distribution year and issued guidance (Notice 2024‑35 and Announcement 2025‑2) that affects beneficiary rules and the implementation timetable, so some recalculation and plan-amendment timing is extended into 2026 [3] [4] [5].
1. What SECURE 2.0 changed for RMD start age — who and when
SECURE 2.0 moved the RMD starting age upward: the practical rule in current guidance is that RMDs begin at age 73 for individuals who reach age 72 after Dec. 31, 2022; the law also phases the starting age to 75 for people reaching age 74 after Dec. 31, 2032 [2] [1]. Multiple adviser summaries and IRS notices reiterate that if you turn 73 in 2025, your RMD obligation is for the 2025 tax year and you can delay the first distribution until April 1, 2026 — but you must still take the 2026 RMD by Dec. 31, 2026 [1] [6].
2. IRS guidance and delays that matter for 2026 recalculation
The IRS finalized substantial RMD regulations in 2024 but then extended the anticipated applicability date for certain proposed rules into the 2026 distribution calendar year via Announcement 2025‑2 and related notices, giving sponsors and recordkeepers extra implementation time [3] [4]. Groom Law Group and Grant Thornton explain the extension covers proposed sections implementing SECURE changes and that the new effective date is no earlier than the 2026 distribution year [3] [4].
3. What that delay means for plan sponsors and individuals
Plan sponsors generally don’t have to fully amend plan documents until the end-of-2026 deadlines for most plans (with later deadlines for collectively bargained and governmental plans), which lets administrators “operate as if” the rules are in effect while postponing formal amendments [5] [7]. Advisory firms warn sponsors and recordkeepers they still must apply the law correctly in practice even while amendment deadlines are delayed, and beneficiaries and participants should ensure account and beneficiary data are accurate for correct RMD calculations [5] [8].
4. How beneficiaries’ RMDs and the 10‑year rule interact in 2026
The SECURE Act’s 10‑year rule for many inherited accounts and subsequent IRS final regulations clarified beneficiary distribution timing; relief that waived certain beneficiary RMDs through 2024 expired and the 10‑year rule has been in force for years starting in 2025, with IRS guidance specifying annual requirements in years one through nine in some cases [9] [10] [11]. Some industry writeups note the IRS extended certain relief and then set final rules that apply going forward, so beneficiaries must follow updated timing and calculation guidance as reflected in the IRS materials [9] [12].
5. Practical effects on RMD calculation for 2026
For account owners the basic RMD calculation still uses the prior-year Dec. 31 account balance divided by the IRS life-expectancy factor (Uniform Lifetime or Joint-Life tables as applicable); the SECURE changes affect who is required to take distributions and when, but not the divisor method itself in ordinary cases [13] [14]. Advisors and outlets emphasize that delaying a first RMD to April 1 of the following year results in two distributions in that calendar year — a common tax-planning pitfall to watch for in 2026 [1] [6].
6. Disagreements, limits, and what’s not in the record
Reporting is consistent that the RMD age is 73 for the current cohort and that IRS notices delayed some regulatory applicability until 2026 [1] [3]. Available sources do not mention any additional statutory change to the RMD start age that takes effect specifically in 2026 beyond the schedule already set by SECURE 2.0 and the IRS effective-date adjustments; they also do not claim a wholesale recalculation method change for 2026 beyond finalized regulations and implementation timing (not found in current reporting). Some industry pieces differ slightly on whether final rules were to apply in 2025 versus 2026—IRS notices and firm summaries explain the phased applicability and the relief extensions and should be read together [12] [3].
Actionable takeaway: If you turn 73 in 2025 or later, plan as if RMDs for the 2025 tax year are due (first payment possibly by Apr. 1, 2026), confirm beneficiary designations and Dec. 31 balances for accurate 2026 calculations, and check with your plan sponsor or tax advisor about how your plan is implementing the IRS’s delayed effective dates and any plan amendments [1] [5] [3].