Can I File Form 5329 by Itself? Missed RMDs, Waivers, and Exceptions

You can file Form 5329 by itself in two situations: when you owe one of the retirement-account penalties it covers but aren’t otherwise required to file a federal income tax return, or when you already filed your return for a prior year and later discover you owe one of those penalties. In both cases you print, sign, and mail the form on its own. Standalone Form 5329 cannot be e-filed.¹

When Standalone Filing Applies

The first situation is the retiree with income below the filing threshold who still owes a penalty. Someone whose only income is Social Security and a small traditional IRA distribution may owe no income tax at all, but if that distribution came out before age 59½, the 10% early withdrawal tax still applies. Form 5329 is how it gets reported and paid.¹

The second is more common: you filed your return for a given year and later realize you missed a required minimum distribution or made an excess contribution. Rather than amend the whole return, you send a standalone Form 5329 for that year. If you have other changes to that return beyond the penalty, you attach the form to a Form 1040-X instead.¹

Why It’s Worth Filing Even for Old Mistakes

The IRS’s three-year window for assessing additional tax only starts running once the relevant return is filed. For the penalties Form 5329 covers, that return is Form 5329 itself.² If you missed an RMD years ago and never filed the form, the assessment clock never started. Filing starts it. Once three years pass from the filing date, the IRS generally cannot assess the penalty for that year. Waiting doesn’t make old missed RMDs disappear; it keeps the exposure open.

Use the Form for the Year the Penalty Occurred

Always use the version of Form 5329 that matches the tax year of the penalty-triggering event. A 2023 missed RMD goes on the 2023 form. Prior-year forms are on the IRS website.³ Using the wrong year’s form causes processing delays.

If you missed RMDs across several years, you file a separate Form 5329 for each year. Married couples where both spouses owe a penalty each file their own. All the forms can go in one envelope, but each is completed on its own. When filing standalone, put your name, address, and Social Security number at the top, complete only the parts that apply to your situation, and sign and date the bottom.¹

Missed RMD: Reporting and Requesting a Waiver

Failing to take a required minimum distribution triggers an excise tax equal to 25% of the shortfall, meaning the difference between what you should have withdrawn and what you actually took. The rate drops to 10% if you correct the shortfall within a correction window that generally runs through the end of the second tax year after the penalty year. To get the reduced rate you need to both take the missed distribution and file Form 5329 before that window closes.⁴

Missed RMDs are reported in Part IX. You enter the amount you should have received and the amount you actually received; the difference is what the penalty applies to.¹

The IRS can waive the penalty entirely if the shortfall resulted from a reasonable error and you are taking steps to fix it.⁴ To request the waiver, write “RC” and the shortfall amount in parentheses on the dotted line next to line 54a or 54b, then subtract that amount so the line shows zero (or whatever portion you are not asking to be waived). Attach a short written statement explaining what happened and what you have done to correct it.¹

The IRS does not publish a list of acceptable excuses specific to missed RMDs, but its general reasonable-cause guidance covers serious illness, death of an immediate family member, inability to obtain records, and natural disasters.⁵ A custodian that failed to process a distribution request, or a beneficiary who inherited an IRA without knowing about the RMD rules, are common scenarios where relief is granted. Keep the explanation short and factual.

Claiming an Early-Distribution Exception

Distributions from a qualified plan or IRA before age 59½ generally carry a 10% additional tax on the taxable portion, reported in Part I. If your 1099-R already shows the correct exception code in box 7 and the exception covers the full distribution, you don’t need Form 5329 at all. You need it when the 1099-R doesn’t reflect the exception, or when the exception applies to only part of the distribution.¹

You enter the applicable exception code on line 2 and the excepted amount next to it; that amount reduces what’s subject to the 10% tax. Exceptions include substantially equal periodic payments, total and permanent disability, death of the account holder, unreimbursed medical expenses over 7.5% of adjusted gross income, qualified higher education expenses from an IRA, up to $10,000 from an IRA for a first-time home purchase, qualified birth or adoption distributions up to $5,000 per event, and distributions after a physician-certified terminal illness. The full list of codes is in the instructions.¹

Excess Contributions

Contributing more than the annual limit to a tax-favored account triggers a 6% excise tax on the excess, assessed every year the excess remains in the account.⁶ This covers traditional IRAs, Roth IRAs, health savings accounts, Archer MSAs, Coverdell education savings accounts, and ABLE accounts, each with its own part on the form (Parts III through VIII).

The simplest fix is to withdraw the excess and any earnings on it before the tax filing deadline, including extensions, for the year of the contribution.⁷ Miss that deadline and the 6% applies for the contribution year and each subsequent year until you either withdraw the excess or absorb it against a later year’s contribution room. Form 5329 is how you report and pay that recurring penalty, and it’s a common reason to file the form standalone year after year until the excess is resolved.

Mailing and Payment

A standalone Form 5329 is due at the same time and goes to the same address as Form 1040 would for that tax year.¹ The correct address depends on your state of residence and is listed in the Instructions for Form 1040. If you are requesting a waiver, put your explanation letter directly behind the signed form. Keep a copy of everything, along with proof of mailing.

You can pay through IRS Direct Pay at irs.gov/payments, which transfers funds from a bank account at no charge. You can also mail a check or money order payable to “United States Treasury,” with your Social Security number and the tax year written on the payment. The IRS cross-references your figures against the 1099-R forms your financial institution filed, so numbers that don’t match will trigger an automated notice. Processing a standalone filing typically takes several weeks.

1
Internal Revenue Service. Instructions for Form 5329 (2025)
2
Office of the Law Revision Counsel. 26 USC 6501 – Limitations on Assessment and Collection
3
Internal Revenue Service. About Form 5329, Additional Taxes on Qualified Plans (including IRAs) and Other Tax-Favored Accounts
4
Office of the Law Revision Counsel. 26 USC 4974 – Excise Tax on Certain Accumulations in Qualified Retirement Plans
5
Internal Revenue Service. Penalty Relief for Reasonable Cause
6
Office of the Law Revision Counsel. 26 US Code 4973 – Tax on Excess Contributions to Certain Tax-Favored Accounts and Annuities
7
Internal Revenue Service. IRA Year-End Reminders