New RMD Regulations Delayed Until 2027
- Lauren Mamaghani
- 3 minutes ago
- 2 min read
Last month, the Treasury Department and IRS (the “Agencies”) released Announcement 2026-7, stating that they anticipate future regulations finalizing certain portions of the 2024 proposed regulations governing required minimum distributions under Code Section 401(a)(9) (“RMDs”) to take effect no earlier than 2027. Before this announcement, these regulations were anticipated to take effect in the 2026 distribution calendar year. In the interim (and until the final version of the regulations takes effect), taxpayers must continue to comply with current regulations and apply a reasonable, good-faith interpretation of the statutory provisions.
RMD regulations have been in the works for many years. In 2022, the Agencies published proposed RMD regulations which reflected changes made by SECURE Act 1.0 and additional comprehensive updates. Then, SECURE Act 2.0 instituted a number of RMD rules. In light of SECURE Act 2.0 and the public comments on the 2022 proposed regulations, in July 2024 the Agencies released two sets of RMD regulations, one final and one proposed.
The 2024 proposed regulations—the subject of Announcement 2026-7—were originally anticipated to take effect for calendar years beginning on or after January 1, 2025 (with the exception of § 1.401(a)(9)-5(a)(5)(v), relating to the valuation of an annuity contract under the partial annuitization option under Section 204 of the SECURE 2.0 Act), so that they would begin to apply contemporaneously with the 2024 final regulations. However, the Agencies received public feedback that it would be difficult to implement a final version of the 2024 proposed regulations by January 1, 2025, especially given uncertainty about how some proposed requirements would be resolved. In response, the Agencies issued Announcement 2025-2, stating that certain portions (those amending §§ 1.401(a)(9)-4, 1.401(a)(9)-5, and 1.401(a)(9)-6)) of future regulations finalizing the 2024 proposed regulations will apply beginning in the 2026 distribution calendar year. Now, per this latest Announcement, these final regulations will apply in the distribution calendar year that begins no earlier than 6 months after the date that final regulations are issued in the Federal Register.
If you have questions about how best to comply with these requirements, please reach out to your Boutwell Fay attorney.
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