Compliance
Navigating New RMD Deadline Changes and Grace Periods Under SECURE 2.0
Changes to required minimum distribution regulations under employee plans now bring clearer deadlines and grace periods—critical for retirees and plan administrators.
By NomadicTax Research Team • 5-8 min read • March 22, 2026
## What’s New with RMDs and the Upcoming Regulations
The IRS has recently released **Announcement 2026-7**, declaring that certain portions of the final regulations under IRC §401(a)(9), proposed in **2022**, will apply **no earlier than 6 months after the Regulations are published**. ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai)) Prior to that effective date, taxpayers must use a **reasonable, good-faith interpretation** of the statutory rules. ([irs.gov](https://www.irs.gov/irb/2026-11_IRB?utm_source=openai))
These changes come as part of the implementation of the **SECURE 2.0 Act** (signed into law in December 2022), which among other updates, raised the beginning age for Required Minimum Distributions (RMDs) and altered the rules for Roth/Designated Roth accounts in employer plans. ([irs.gov](https://www.irs.gov/irb/2026-06_IRB?utm_source=openai))
## Key Implications for Individuals and Plan Administrators
- **Flexible application window:** Final regulations aren’t binding until the specified effective date (6 months post-publication). Before that, use good-faith interpretations—don’t presume retroactive application.
- **Age requirements under SECURE 2.0:** For individuals born after Dec. 31, 2022, the age for RMDs is **73** until 2032. After Dec. 31, 2032, it increases to **75**. ([irs.gov](https://www.irs.gov/irb/2026-06_IRB?utm_source=openai))
- **Designated Roth accounts in plans:** Roth accounts under employer plans (Designated Roth) are exempted from RMDs during the lifetime of the original account owner, but beneficiary rules still apply. ([irs.gov](https://www.irs.gov/irb/2026-06_IRB?utm_source=openai))
## Case Study Example
**Example 1—Retiree scenario:**
- Maria turned 73 in January 2024, is retired, and has both a traditional IRA and a 401(k) featuring a Designated Roth.
- Her first RMD under IRA must be taken by **April 1, 2025**, based on her 2024 year-end balance. For the 401(k), because she is retired, beginning date per her plan document applies—and she need not take RMDs from her Designated Roth while alive.
**Example 2—Plan administrator’s work:**
- A company sponsors a 401(k) plan. Its administrators must ensure participant notices reflect that age-73 rules apply now, not age 72, and properly identify designations for Roth and non-Roth accounts. They must also prepare participants for the coming regulation once final rules are issued and effective.
## Actionable Guidance
1. **Review plan documents** now to ensure consistency with age 73 requirement and that Designated Roth accounts are handled per new rules.
2. **Educate participants** who are 70-plus on upcoming RMD timing, so they aren’t caught by deadlines (e.g., April 1 vs. December 31) without understanding.
3. **Document good-faith interpretations**: until final regulations are in place, employ reasonable interpretations and maintain writing or memos supporting decisions.
4. **Plan for system changes**: Adjust internal systems for RMD calculations, notices, and required operations ahead of final regulation publication.
## Why This Matters
Misapplication of RMD rules can lead to substantial tax penalties—excise taxes as high as **25%** (or even 50% depending on past failures) of the amount not distributed as required. Ensuring understanding of the shifting age thresholds and exemptions helps retirees protect their assets and prevents surprises for plan administrators.