Two separate eligibility tests get conflated in most coverage of Trump Accounts: who can have an account at all, and who gets the $1,000 pilot deposit. Many children qualify for the first but not the second. Here are both sets of rules from IRS Notice 2025-68 and the section 6434 proposed regulations, with the boundary cases spelled out.
Test 1: Who can have a Trump Account
An “eligible individual” for account purposes is any child who:
- has not turned 18 before the end of the calendar year in which the account election is made, and
- has a Social Security number.
That is the whole test. There is no income limit, no requirement that the child (or the parents) have earned income, and no citizenship requirement for the account itself. A 10-year-old born in 2016 can have a Trump Account opened for them in 2026 and receive family and employer contributions for the next several years — they just won’t get the pilot deposit.
Only one Trump Account election can be made per child, and the person who makes it becomes the account’s responsible party. The proposed regulations set a priority order: the parent who can claim the child as a dependent, then either parent, then a legal guardian or grandparent.
Test 2: Who gets the $1,000 pilot deposit
The pilot program (IRC section 6434) is narrower. The child must be:
- born after December 31, 2024 and before January 1, 2029 — i.e. born 2025, 2026, 2027, or 2028,
- a qualifying child (under the section 152(c) dependent rules) of the person making the election,
- a U.S. citizen, and
- the holder of an SSN issued before the election is made.
One pilot election per child, ever. The $1,000 is technically treated as a payment against the child’s income tax that the Treasury routes into the account — you never touch the cash. It does not count toward the $5,000 annual contribution cap, and it carries no basis (meaning it is taxable when eventually withdrawn).
The election is made by checking the box on line 7, Part III of IRS Form 4547, or through the trumpaccounts.gov portal.
Boundary cases
Born in 2024 or earlier. Account: yes (until the year they turn 18). Pilot: no — the window starts January 1, 2025. A child born December 31, 2024 misses the $1,000 by one day; one born January 1, 2025 gets it.
Born during 2028. Both: yes. The window runs through December 31, 2028, so babies born right up to the end of 2028 qualify — but the SSN must be issued before the election is filed.
Teenager turning 18. A child who turns 18 during the election year is not an eligible individual — they must still be under 18 at the end of that calendar year. In 2026, that means children born in 2009 or later can have accounts opened; a child born in 2008 cannot.
Non-citizen children. A child who is not a U.S. citizen can still have a Trump Account (the account test has no citizenship requirement) but cannot receive the pilot deposit.
Green-card or visa parents. The citizenship test applies to the child, not the parent. A U.S.-citizen baby born in 2026 to non-citizen parents qualifies for the pilot, provided the child has an SSN and is the electing parent’s qualifying child.
Expecting parents: what about babies due in 2027 or 2028?
You cannot open an account or make the pilot election before the child exists and has an SSN. But there is no rush-to-the-deadline problem: the pilot window covers births through the end of 2028, and elections can be made after birth (Form 4547 with your tax return, or online). What you can do now is plan the contribution budget — the calculator lets you pick a future birth year and see the projection from there.
What eligibility is worth in dollars
The pilot deposit alone, invested in an S&P 500 index fund at a 7% average return, is worth roughly $3,200 at age 18 with no further contributions. Add the full $5,000 annual cap and it’s around $173,000. Check your child’s numbers — birth year, contributions, and the tax treatment at withdrawal — with the Trump Account Calculator, and see Trump Accounts Explained for the full rulebook.