Which retirement account types (traditional IRAs, SEP, SIMPLE, 401(k), Roth 401(k)) are affected by the 2026 RMD rule changes?
Executive summary
The RMD changes slated for the 2026 distribution year affect traditional, pre‑tax retirement accounts — specifically traditional IRAs and employer plans such as 401(k)s, 403(b)s and eligible 457(b) plans — and also cover SEP and SIMPLE IRAs; designated Roth accounts in employer plans are generally exempt while Roth IRAs remain exempt during an original owner’s lifetime [1] [2] [3]. The IRS has delayed some proposed RMD regulation changes so the final rules will not apply earlier than the 2026 distribution calendar year [4] [5].
1. Which account types the 2026 RMD changes target — the short answer
The policy and regulatory activity described in current reporting applies to required minimum distributions from tax‑favored, pre‑tax accounts: traditional IRAs (including SEP and SIMPLE IRAs) and employer‑sponsored defined contribution plans such as 401(k), 403(b) and eligible 457(b) plans [1] [2]. The IRS guidance and industry write‑ups group those accounts together when explaining SECURE 1.0 and SECURE 2.0 related updates and the 2026 applicability delay [5] [4].
2. Roth accounts: treated differently and why it matters
Designated Roth accounts inside employer plans (Roth 401(k)/403(b)) are no longer subject to RMDs while the original owner is alive under SECURE 2.0 changes, mirroring the long‑standing exemption for Roth IRAs; however inherited Roth accounts remain subject to distribution rules [2] [3] [1]. Multiple outlets highlight that the prior discrepancy — Roth IRAs exempt, Roth 401(k)s not — has been addressed, which is the clearest carve‑out in the recent law and regulation discussion [2] [3].
3. What the IRS delay means for plan sponsors and participants
The IRS announced that the final regulations proposed in 2024 will not apply any earlier than the 2026 distribution calendar year, giving plan sponsors and recordkeepers extra time to implement new rules tied to sections of the RMD regulations (notably 1.401(a)-4, -5 and -6) and signaling that taxpayers may use a reasonable, good‑faith interpretation for the interim period [4] [5]. Industry advisors explicitly say this extension was motivated by practical implementation concerns raised in public comment [5].
4. How the “still‑working” exception and employer plans fit into the picture
The longstanding “still‑working” exception — which can let non‑5% owners postpone RMDs from an employer plan until after they retire — remains relevant and applies differently across account types: it does not apply to IRAs, including SEP and SIMPLE IRAs, but does apply to many employer plans [6] [7]. That distinction is highlighted repeatedly in IRS and advisory materials and influences whether a worker must begin RMDs while still employed [7].
5. Penalties, timing and practical takeaways for savers
The reduced excise tax for missed RMDs (generally a 25% penalty and possibly 10% if corrected quickly) and the standard deadlines — RMDs generally due by December 31, with a first‑year deferral until April 1 of the following year — remain central operational rules to watch as the new regulations finalize [8] [9] [10]. Financial outlets and the IRS recommend that account owners and plan administrators update withdrawal strategies and communications in light of both statutory changes and the IRS’s delayed effective date [8] [5].
6. Where reporting agrees, and where details remain unsettled
Sources agree on which account types are within the RMD framework (traditional IRAs, SEP/SIMPLE IRAs, 401(k)/403(b)/457(b) plans) and on the Roth carve‑out for original owners [1] [2] [3]. What remains unsettled in public reporting is the final form of certain technical regulatory provisions and operational rules that the IRS has postponed to 2026 — those proposed rules involve implementation mechanics and QLAC treatment cited by legal commentators [5]. Available sources do not mention finalized text for every operational detail, so plan sponsors are being given a year to adjust [4] [5].
7. Practical next steps for account owners and plan sponsors
Account holders should confirm whether their Roth balances are in designated employer Roth accounts or Roth IRAs (different rules on RMDs while alive), check whether they can use the still‑working exception for an employer plan, and work with advisors to model tax impact of taking RMDs [3] [7] [10]. Plan sponsors and recordkeepers must monitor the IRS’s final regulations expected no earlier than the 2026 distribution year and prepare administrative changes now that the IRS has publicly extended the effective date [4] [5].
Limitations: this analysis uses the sources provided above; if you want direct quotations from the IRS proposed or final regulatory text or the exact regulatory language for sections 1.401(a)-4, -5 and -6, those documents are not included in the supplied material and therefore not cited here (not found in current reporting).