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25 February 2026

Future RMD regulations will not apply until at least six months after finalization

  • Under Announcement 2026-7, future final regulations amending the required minimum distribution rules under IRC Section 401(a)(9) will not apply before the distribution calendar year that begins at least six months after the final regulations are published in the Federal Register.
  • Until those regulations are effective, taxpayers may continue to apply a reasonable, good-faith interpretation of the statutory required minimum distribution rules, taking into account existing regulations and prior guidance.
  • The extended lead time responds to concerns from plan sponsors, recordkeepers and other stakeholders about the operational challenges of implementing the 2024 proposed regulations on the original January 1, 2025, applicability timeline.
 

In Announcement 2026-7, the Treasury Department and IRS announced that final regulations amending certain provisions of the required minimum distributions (RMDs) rules are anticipated to apply for the distribution calendar year that begins no earlier than six months after the date those final regulations are published in the Federal Register.

For all periods before that applicability date, taxpayers must continue to apply a reasonable, good-faith interpretation of the underlying statutory provisions.

Background

In final regulations (TD 10001) published July 19, 2024, the IRS and Treasury Department updated the RMD rules to reflect changes made by the Setting Every Community Up for Retirement Enhancement (SECURE) Act and the SECURE 2.0 Act. The regulations affect retirement plan participants, IRA owners and their beneficiaries, as well as administrators and custodians of retirement plans and IRAs (see Tax Alert 2024-1945). At the same time, proposed regulations were released addressing additional RMD issues and incorporating certain SECURE 2.0 Act provisions.

The 2024 proposed regulations were generally proposed to apply for distribution calendar years beginning on or after January 1, 2025, so that they would begin to apply at the same time as the 2024 final regulations.

The Treasury Department and IRS subsequently issued Announcement 2025-2, which stated that the anticipated applicability date in the regulations finalizing the proposed regulations amending Treas. Reg. Sections 1.401(a)(9)-4, 1.401(a)(9)-5 and 1.401(a)(9)-6 would be no earlier than the 2026 distribution calendar year.

Announcement 2026-7

Announcement 2026-7 states that when the 2024 proposed regulations are published as final, the provisions amending Treas. Reg. Sections 1.401(a)(9)-4, 1.401(a)(9)-5 and 1.401(a)(9)-6 will apply for purposes of determining RMDs for the distribution calendar year that begins no earlier than six months after the date those final regulations are published in the Federal Register.

Implications

Announcement 2026-7 extends existing transition relief pending publication of final regulations and does so in a manner that will not require the IRS to take any action to extend it further in case the final regulations are not published in time to apply in 2027. Importantly, however, this transition relief does not apply to any of the rules in the July 2024 final regulations.

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Contact Information

For additional information concerning this Alert, please contact:

Compensation and Benefits Group

Published by NTD’s Tax Technical Knowledge Services group; Andrea Ben-Yosef, legal editor

Document ID: 2026-0513

 

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