RMD Rules & Guidance
A working reference to the rules this calculator applies, current to the SECURE 2.0 applicable ages and the final regulations issued 19 July 2024. Written for people who process distributions rather than for participants.
The trap most calculators still get wrong
Between the SECURE Act in 2019 and the final regulations in 2024, the industry genuinely did not know whether a beneficiary subject to the 10-year rule also owed annual RMDs along the way. Many tools were written during that gap and never revisited.
The final regulations settled it, and the answer depends on one fact:
If the participant died before the RBD, the 10-year rule is clean: no annual RMD, just the year-10 deadline.
The practical consequence is that an adult child inheriting from a 76-year-old and an adult child inheriting from a 68-year-old are on completely different schedules, and a tool that treats them alike will understate one of them. The IRS waived the missed annual amounts for 2021 through 2024 under Notices 2022-53, 2023-54 and 2024-35 — no penalty and no make-up — so enforcement effectively begins with the 2025 distribution year.
When distributions must begin
Applicable age
SECURE 2.0 §107 replaced a single RMD age with a ladder keyed to date of birth. The 1949 boundary falls mid-year, which is the detail most often missed.
| Date of birth | Applicable age | Why |
|---|---|---|
| Before 1 July 1949 | 70½ | Reached 70½ before 2020, so the pre-SECURE rule was locked in |
| 1 July 1949 – 31 Dec 1950 | 72 | SECURE 1.0 |
| 1951 – 1959 | 73 | SECURE 2.0. The 1959 birth year was ambiguous in the statute; the 2024 proposed regulations assign it 73 |
| 1960 or later | 75 | SECURE 2.0 |
Required Beginning Date
The RBD is 1 April of the year following the year the applicable age is reached — not 1 April of that year. Someone who turns 73 in 2026 has an RBD of 1 April 2027.
The still-working exception
A participant who is still employed may defer the RBD to 1 April following the year of retirement — but only where all three hold:
- The account is an employer plan — 401(k), 403(b) or governmental 457(b). IRAs, SEP and SIMPLE IRAs never qualify, regardless of employment.
- The participant is not a 5% owner. Ownership is tested for the plan year ending in the calendar year the participant reaches the applicable age; once a 5% owner at that point, always a 5% owner for this purpose.
- The plan document actually permits the deferral. It is optional, and not every plan adopts it.
Roth accounts
Roth IRAs have never carried a lifetime RMD. Since 2024, under SECURE 2.0 §325, neither do designated Roth accounts in a 401(k), 403(b) or governmental 457(b) — though RMDs were still required from those accounts for 2023 and earlier. A Roth owner therefore has no RBD, which means their beneficiaries are always treated as inheriting before the RBD.
Which table applies
| Table | Used for | Method |
|---|---|---|
| III — Uniform Lifetime | Nearly every living participant | Attained age in the distribution year |
| II — Joint Life & Last Survivor | Only where the spouse is the sole beneficiary for the entire year and is more than 10 years younger | Both attained ages, tested afresh each year |
| I — Single Life | Beneficiaries of a deceased participant | Fixed term reduced by one each year, except a sole spouse who recalculates |
Two details worth holding on to. The Table II threshold is more than 10 years, so a spouse exactly 10 years younger does not qualify. And a sole surviving spouse recalculates — looking up Table I afresh at their attained age each year — rather than subtracting one. Every other beneficiary subtracts one.
Classifying a beneficiary
After a death, almost everything turns on which of three categories each beneficiary falls into. Status is fixed as of the participant's death, except that beneficiaries themselves are finally determined on 30 September of the year following death — leaving room for a qualified disclaimer within nine months, or a full cash-out of a share, to change the outcome.
| Category | Who | Died before RBD | Died on/after RBD |
|---|---|---|---|
| EDB Eligible Designated Beneficiary | Surviving spouse; minor child of the participant; disabled; chronically ill; anyone not more than 10 years younger | Life expectancy, or elect the 10-year rule | Life expectancy, never shorter than the participant's own remaining life expectancy |
| NEDB Non-Eligible Designated Beneficiary | Adult children, grandchildren, most other individuals, see-through trusts for them | 10-year rule, no annual RMD | Annual RMDs in years 1–9 and empty by year 10 |
| NDB Non-Designated Beneficiary | Estate, charity, any non-person, non-see-through trust | 5-year rule | The participant's remaining life expectancy — the “ghost” rule |
Points that catch people out
- Minor child means the participant's own child. A grandchild, niece or nephew under 21 is not an EDB. And the exception ends at 21, not at the age of majority: life-expectancy payments run until the child turns 21, then the 10-year rule takes over, so the account must be empty by 31 December of the year they turn 31.
- Charities are corrosive. Naming a charity alongside individuals, without separate accounts, makes the whole account a Non-Designated Beneficiary account. A 10% charitable share can put the other 90% on the 5-year rule.
- Separate accounts must be established by 31 December of the year following death. Do it and each beneficiary uses their own life expectancy and their own category. Miss the date and everyone is measured by the oldest beneficiary and by the least favourable category present.
- A see-through trust is not an estate. A conduit trust generally passes the underlying beneficiary's status straight through. An accumulation trust is usually treated as a Non-Eligible Designated Beneficiary, unless it qualifies as an applicable multi-beneficiary trust for a disabled or chronically ill beneficiary.
Surviving spouses
A spouse has more options than anyone else. They may roll the balance over or treat an inherited IRA as their own, which restarts the ordinary owner rules from scratch. If they stay a beneficiary, they may defer the start of payments until the year the participant would have reached the applicable age. And since 2024, SECURE 2.0 §327 lets a sole spouse elect to be treated as the participant — using the Uniform Lifetime table rather than Table I, which produces a materially smaller distribution. For plan accounts where death occurred before the RBD, that treatment is the default.
Deadlines, aggregation and getting it wrong
Year-of-death RMD
If a participant dies on or after their RBD, their own RMD for the year of death still has to come out, and it is the beneficiaries who must take it. The final regulations automatically waive the excise tax if it is distributed by the beneficiary's tax filing deadline for the year following death.
Aggregation
- An RMD is calculated separately for every account, always.
- IRA RMDs may then be totalled and taken from any one IRA. The same applies within 403(b) contracts, separately.
- 401(k), governmental 457(b) and other qualified plan RMDs may not be aggregated — each plan pays its own.
- Inherited accounts aggregate only with other inherited accounts from the same decedent, and never with the beneficiary's own.
Missed distributions
A shortfall carries a 25% excise tax under IRC §4974, reduced to 10% if corrected within the correction window — broadly, by the end of the second year following the year of the shortfall. File Form 5329 and request a waiver where reasonable cause applies; the IRS grants these routinely on a clean explanation. Plan-level failures may also be corrected under EPCRS.
Years that do not count
- 2020: all RMDs were waived by CARES Act §2203. The year is also disregarded in applying the 5-year rule, extending that deadline by a year for deaths from 2015 to 2020.
- 2021–2024: annual RMDs under the 10-year rule were waived by Notices 2022-53, 2023-54 and 2024-35. No penalty, and no requirement to make them up.
- Deaths before 2020 predate the SECURE Act entirely. A designated beneficiary keeps full life-expectancy treatment, with the initial factor redetermined under the 2022 tables and reduced by one for each year elapsed.