RMD Final Regulations Delayed: Announcement 2026-7 and Dates

What Announcement 2026-7 says

The announcement is one page of operative text. Its purpose paragraph says the Treasury Department and the IRS “anticipate that certain portions of final regulations relating to required minimum distributions” will apply for “the distribution calendar year that begins no earlier than 6 months after the date that final regulations are issued in the Federal Register.” Section III names the portions: “Final regulations amending §§ 1.401(a)(9)-4, 1.401(a)(9)-5, and 1.401(a)(9)-6, issued pursuant to the 2024 proposed regulations.” For earlier periods, “taxpayers must continue to apply a reasonable, good-faith interpretation of the statutory provisions underlying the regulations.”

The reason given is implementation. Commenters, at the hearing of September 25, 2024 and in writing, said it “would be difficult to implement many of the provisions of the future final regulations in a timely manner” and raised specific concerns about the amendments to -4, -5 and -6.

The announcement is a statement of what the agencies “anticipate”. It is not a regulation, it fixes no calendar year, and it does not say what a good-faith interpretation is. One thing it leaves out is worth noting. When the 2024 final rule dealt with years before 2025 for the SECURE Act items, it said: “Compliance with the proposed regulations will satisfy that requirement.” Section III of Announcement 2026-7 has no sentence like that (our reading), so the 2024 proposal is one possible good-faith reading, not a stated safe harbor.

Source: Internal Revenue Bulletins 2025-2 and 2026-11; Federal Register documents 2024-14542 and 2024-14543. The last row is our check, described below.

Is there a final rule? What we checked on November 3, 2026

We found no final regulation as of November 3, 2026. Three checks, each saved with the page:

• The docket. A Federal Register API search for REG-103529-23 returns two documents, the July 19, 2024 proposal (document 2024-14543) and the July 19, 2024 final rule (document 2024-14542). Nothing later.
• The subject. A search for “required minimum distributions” among documents published since July 20, 2024 returns two items, a Thrift Savings Plan Roth rule and a Labor Department lost-and-found notice. Neither is a Treasury RMD rule. A search of IRS rules that mention SECURE 2.0 since then finds a catch-up contribution rule and two conservation-easement rules.
• That the index is current. The newest IRS document in the same API is dated November 3, 2026.

The Unified Agenda entry for this rule (RIN 1545-BQ66, “SECURE 2.0 Updates to Required Minimum Distribution Rules”) is in the Final Rule Stage with no legal deadline. The Spring 2025 edition listed the final action as 05/00/2026. The entry on reginfo.gov labelled 2026 lists 07/00/2026. Both are month-and-year targets, and both months are over. We did not find a later edition on reginfo.gov.

The arithmetic: which year can the delayed rules start (our arithmetic)

The formula is “the distribution calendar year that begins no earlier than 6 months after” publication. For IRAs and plans on the calendar year, take the publication date, add six months, and the first January 1 on or after that date is the earliest first year.

Our arithmetic on the formula in Announcement 2026-7. The announcement states no year. The agencies may choose a later date than the earliest one.

Four examples (our arithmetic): a rule published November 17, 2026 gives May 17, 2027 and a 2028 start; March 1, 2027 gives September 1, 2027 and 2028; July 1, 2027 gives January 1, 2028 and still 2028; July 2, 2027 gives January 2, 2028 and 2029. The one-day difference at the July 1 line moves the start by a whole year, so the publication date matters more than the month in which a rule is signed.

The slug of this page says 2028 because that is the earliest year the arithmetic allows. It is not a forecast: the rule has not been published and the Unified Agenda target for it moved from May 2026 to July 2026 and has now passed.

What the delay covers and what it does not

The announcement names regulation sections, not topics. To see which proposed changes sit in those sections we read the 2024 proposal paragraph by paragraph. The first five rows are in sections -4, -5 and -6; the last four are in other sections (our reading).

Source: 89 FR 58644 (proposal, document 2024-14543) and Announcement 2026-7, section III. The last four rows are in sections the announcement does not name. We did not find any document that says what happens to them, so they stay proposed until a final rule appears (our reading).

Two points on that table. First, the delayed items are mostly about employer plans. The spousal election in the proposal is written for defined contribution plans, and the preamble says the election “does not affect the ability of the employee’s surviving spouse to make a rollover to the spouse’s own IRA or to treat an IRA as the surviving spouse’s own IRA.” Our surviving spouse IRA page walks through that IRA route. Second, one thing that sounds like part of the delay is not: the 2024 final regulations already exclude a designated Roth account from the balance used to compute a plan RMD, up to and including the year of death. The proposed Roth paragraph is the separate question of whether a Roth withdrawal can count toward the RMD.

What applies to you now

While the rule is pending, the final regulations of July 19, 2024 apply to calendar years beginning on or after January 1, 2025. For the delayed items, the announcement says to apply a reasonable, good-faith interpretation of the statute. In practice the plan administrator or IRA custodian decides how its documents read (our reading), so the question for a reader is which of these situations applies.

Surviving spouse of a plan participant. The final rule did not write the election: it says the rules “are reserved in these final regulations and included in a notice of proposed rulemaking.” The proposal would make the election automatic when the employee died before the required beginning date and the spouse is the sole beneficiary, would use the Uniform Lifetime Table instead of the Single Life Table, and would limit the election to cases where the first year of annual RMDs to the spouse is 2024 or later. If you inherited an IRA rather than a plan account, you can still treat it as your own or roll it over.

Roth 401(k) or Roth 403(b) money. The proposal says that a distribution from a designated Roth account in a year an RMD is required “would not count towards satisfying that requirement.” If that is adopted, a worker whose plan requires an RMD from the pre-tax part cannot meet it by taking Roth money. Our worked example (our arithmetic): the RMD from the pre-tax part is $25,000 (assumed) and the person takes $40,000 from the Roth account only. As proposed, the shortfall is the full $25,000, and the excise tax is $6,250 at 25 percent or $2,500 at 10 percent if the correction rules apply. Whether a plan lets Roth money count in the meantime is a plan question; see our page on RMDs for people still working for the Roth balance rule already in force.

A missed RMD. The 25 percent to 10 percent reduction is in the final rule, not the proposal, and is not delayed. What the proposal adds is that “if a missed required minimum distribution is corrected by a distribution made in a subsequent calendar year, the required minimum distribution for that subsequent year must be made in addition to the corrective distribution.” With the assumed numbers, a $25,000 missed RMD for 2026 corrected in 2027 plus a $27,000 RMD for 2027 means $52,000 out in 2027 (our arithmetic). For the IRS relief route see our page on the IRA Compliance Resolution System.

A QLAC bought before a divorce. The proposed divorce rule would be “available only if the plan is not subject to both section 414(p) of the Code and section 206(d) of ERISA”. Our QLAC page covers the premium limit, the start date and the RMD effect.

An IRA with illiquid assets. Nothing in the announcement changes how an IRA RMD is computed or satisfied. The practical limits on paying an RMD from an asset you cannot sell are on our illiquid IRA RMD page, and the divisors are on the Uniform Lifetime Table page.

What a reader can do with this

• Sort your accounts into employer plan, traditional IRA, Roth IRA and designated Roth account in a plan, because the delayed items mostly touch the first and last.
• Ask the plan in writing how it treats a Roth withdrawal in an RMD year, a surviving-spouse beneficiary of a participant, and a corrective distribution, and keep the answer.
• Do not wait for the final rule to take an RMD. The announcement delays the new text, not the duty to take an RMD under the statute and the 2024 final rule.
• If you missed an RMD, read the 25 percent and 10 percent rules and the correction window before paying the shortfall, and ask whether the payment will be treated as extra to the next year’s RMD.
• Check the Federal Register for docket REG-103529-23 or RIN 1545-BQ66 before assuming a start year; the arithmetic above gives the year once a date exists.

What to ask your adviser or CPA

1. Which of my accounts are plans and which are IRAs, and which are designated Roth accounts?
2. How does my plan document read on Roth withdrawals, spouses and corrective distributions while the rule is pending?
3. If a final rule is published in 2027, which year would it first apply to me?
4. If I missed an RMD, what do I pay, by when, and how does it interact with the next RMD?

This is analysis of public documents, not investment, legal or tax advice. The people who can say how a plan applies a good-faith reading are the plan administrator and a CPA or tax attorney who has your plan documents.

FAQ

Sources, read and saved on November 3, 2026: IRS Announcement 2026-7 (Internal Revenue Bulletin 2026-11, March 9, 2026, page 697) and Announcement 2025-2 (Internal Revenue Bulletin 2025-2, January 6, 2025, page 305); Federal Register documents 2024-14543 (89 FR 58644, proposed rule, REG-103529-23) and 2024-14542 (89 FR 58886, final rule); Federal Register API searches of November 3, 2026; Unified Agenda entry RIN 1545-BQ66 (reginfo.gov, Spring 2025 edition and the edition labelled 2026). Year ranges, day counts and the worked examples are our arithmetic; the reading of which proposed paragraph falls in which named section is ours. The build script is saved with the page.