The SECURE 2.0 Act, signed 29 December 2022 as part of the Consolidated Appropriations Act of 2023, made two structural changes to RMDs that govern every IRA and 401(k) owner approaching retirement age. The first was a phased increase in the Required Beginning Date (RBD) from 72 to 75. The second was a steep reduction in the penalty for missing an RMD.
For 2026 distributions, two cohorts of retirees are affected: those born 1951-1953 are in their first three RMD years; those born 1954-1959 are still pre-RBD but should plan for an age-73 trigger; and the much larger cohort born 1960+ will not face their first RMD until 2033 at the earliest. The age-75 group has the longest pre-RBD planning window in modern tax history — and the largest opportunity to compress Roth conversions, QCDs, and asset-location moves before mandatory distributions begin.
For the full table of divisors, see the 2026 RMD Table guide.
1. The age timeline — who hits RBD in which year
The SECURE 2.0 §107 split the RMD age into two buckets by birth year. There is no formal phase-out for those born 1959 → 1960 — the divide is hard:
| Birth year | First RMD year (age at year-end) | RBD (first distribution deadline) |
|---|---|---|
| 1950 | 2022 (turned 72; pre-SECURE 2.0) | 1 April 2023 |
| 1951 | 2024 (turned 73) | 1 April 2025 |
| 1952 | 2025 (turned 73) | 1 April 2026 |
| 1953 | 2026 (turning 73) | 1 April 2027 |
| 1954 | 2027 | 1 April 2028 |
| 1955 | 2028 | 1 April 2029 |
| 1956 | 2029 | 1 April 2030 |
| 1957 | 2030 | 1 April 2031 |
| 1958 | 2031 | 1 April 2032 |
| 1959 | 2032 | 1 April 2033 |
| 1960 | 2035 (age 75 jump) | 1 April 2036 |
| 1961 | 2036 | 1 April 2037 |
Note that 1959-born retirees are the last to use the age-73 trigger. Anyone born 1 January 1960 or later waits until age 75. There is no “split-the-baby” — even someone born on 31 December 1959 uses 73; someone born one day later uses 75.
2. The first-RMD April-1 trap
The Required Beginning Date — the calendar deadline for the first RMD — is 1 April of the year after the year you reach RBD age. Every subsequent year’s RMD must be taken by 31 December of that year.
This creates a one-time choice in the first RMD year:
- Take the first RMD in the year you turn 73: standard Dec-31 deadline; one taxable distribution per calendar year.
- Defer the first RMD until 1 April of the following year: the second RMD (for that next calendar year) is still due by 31 December — two RMDs in one calendar year.
Doubling up two years of RMD income often pushes retirees:
- Into a higher marginal bracket (especially the 22% → 24% step at $103,350 single / $206,700 MFJ in 2026, or 24% → 32% at $197,300 single / $394,600 MFJ).
- Across the IRMAA Medicare-premium thresholds (Part B and Part D surcharges based on MAGI from 2 years prior).
- Over the Social Security 85% taxability threshold (provisional income $34,000 single / $44,000 MFJ).
The April-1 deferral is rarely the right choice unless a one-year income drop is expected (early-retirement gap year, large deductible loss carryforward, planned charitable distribution).
When the deferral is worth it
Eve will turn 73 in 2026. Her 2026 taxable income (before RMD) is projected at $180,000 — well into the 24% bracket. Her 2027 projected income is $90,000 because she is selling rental property and using a §1031 deferred-exchange that pushes most gain into 2028.
- Take 2026 RMD in 2026: $42,000 RMD × 24% = $10,080 federal tax.
- Defer to April 2027: Both 2026 and 2027 RMDs taxed at the 2027 marginal rate of 22% (after the rental income drops out). $84,000 × 22% = $18,480.
- Savings from deferral: $10,080 + (2027 RMD at 24% = $10,080) = $20,160 standalone vs $18,480 stacked = $1,680 saved.
Without the 2027 income drop, the stacked-year approach would have cost more, not less. The deferral only helps when next year’s marginal rate is meaningfully lower than the current year’s.
3. Penalty reduction — from 50% to 25%/10%
Before SECURE 2.0, missing an RMD triggered a 50% excise tax on the shortfall under IRC §4974 — one of the steepest penalties in the entire tax code. SECURE 2.0 §302 reduced it effective for tax years after 31 December 2022:
| Scenario | Penalty |
|---|---|
| Standard missed RMD | 25% of shortfall |
| Corrected within 2 years (corrective distribution + Form 5329) | 10% of shortfall |
| First-time reasonable-cause waiver via Form 5329 + statement | Generally 0% |
The 2-year correction window starts on the day after the missed RMD year ends. So a 2026 missed RMD must be distributed and reported by 31 December 2028 to qualify for the 10% rate. Beyond that window, the 25% rate applies.
Form 5329 mechanics for a missed RMD
Three steps:
- Take the missed distribution as soon as the gap is identified.
- Complete Part IX of Form 5329 (“Additional Tax on Excess Accumulation in Qualified Retirement Plans”) for the year the RMD was due.
- Compute 25% (or 10% if within correction window) on line 55, or enter “RC” + the waiver amount on the dotted line and attach a statement requesting waiver for reasonable cause.
For the reasonable-cause waiver, the IRS is generally lenient with first-time first-year mistakes (e.g., custodian failed to compute the RMD; beneficiary unaware of inherited-IRA obligation). The waiver is rare for habitual non-compliance.
4. Still-working exception (employer plans only)
If you continue working past your RBD age for the employer that sponsors your 401(k), 403(b), or other qualified plan, the RBD for that plan only is deferred until 1 April of the year following your retirement.
The exception does not apply to:
- Traditional IRAs, SEP-IRAs, or SIMPLE IRAs (no employer relationship).
- 401(k) or other plans from former employers — RMDs from those plans are still due at age 73/75.
- 5%-or-more business owners (Tier I and Tier II constructive-ownership rules of §318 attribution may apply through family).
- Plans where the still-working exception was not adopted in the plan document (verify with the plan administrator — not all plans accept it even when the law permits).
Consolidating former-employer 401(k)s into the still-working employer’s plan before turning 73 is a common move to extend the deferral — but only if the receiving plan accepts incoming rollovers and the plan document includes the still-working clause.
5. Pre-RBD planning window for the age-75 cohort
Anyone born 1 January 1960 or later has at least 8 years between traditional retirement age and their RMD trigger. This is the longest pre-RBD window any cohort has had since RMDs were introduced in 1974, and it creates a planning opportunity:
- Roth conversion ladder. Converting Traditional IRA balances to Roth in the low-income gap years between retirement and 75 fills lower brackets at today’s known TCJA-era rates. The Roth Conversion Calculator helps size each year’s conversion against IRMAA cliffs.
- Qualified Charitable Distributions are available starting at age 70½ — independent of the RMD age. The age-75 RMD cohort can do QCDs for nearly 5 years before any RMD obligation triggers, satisfying ordinary tax efficiency without RMD pressure. See the 2026 QCD guide.
- Asset location. Pre-RBD years are the time to position high-growth assets in Roth and tax-inefficient bonds in Traditional, knowing that the Traditional balance is what will face mandatory taxable distribution at 75.
- Social Security claiming. Delaying Social Security to 70 (8% annual increase from full retirement age) creates a 5-year gap where Traditional withdrawals are 100% under your control — ideal for Roth-conversion years.
The general rule: every dollar converted to Roth before age 75 is a dollar that never appears in any future RMD calculation. For the age-75 cohort, “every dollar before 75” is a much longer runway than the age-73 cohort had.
6. Practical checklist
For someone reaching their RBD year:
- Confirm prior-year-end balance from each Traditional / SEP / SIMPLE IRA custodian statement.
- Identify all 401(k)/403(b)/457(b) accounts; consolidate into one IRA or current employer plan where possible (avoid the no-aggregation rule for 401(k) RMDs).
- Update beneficiary forms if a younger spouse → Joint Life Table eligibility may apply.
- Decide April-1 deferral vs same-year distribution based on next year’s projected income.
- Set federal withholding on the RMD via Form W-4R if the default 10% would underpay.
- Schedule the QCD (if charitably inclined) before the RMD distribution — once any RMD distribution is taken, that withdrawal cannot be reclassified as a QCD retroactively.