What Accounts Are Subject to RMD Requirements?

Required minimum distributions apply to traditional IRAs, SEP IRAs, SIMPLE IRAs, 401(k) plans, 403(b) plans, and governmental 457(b) plans. Roth IRAs are exempt during the original owner’s lifetime, and since 2024 Roth accounts held inside employer plans share that exemption. Once any of these accounts, Roth or not, passes to a beneficiary, distribution rules kick in.¹

Traditional IRAs, SEP IRAs, and SIMPLE IRAs

If you hold a traditional IRA, you must begin annual withdrawals once you reach the applicable RMD age, whether or not you are still working. SEP IRAs and SIMPLE IRAs work the same way. All three account types sit under the same section of the tax code and share the same distribution framework.²

The reason they are subject to RMDs is that contributions were tax-deductible or tax-deferred. The IRS has not yet collected income tax on that money, and the RMD forces you to draw the balance down so the deferred tax gets paid. Withdrawals count as ordinary income for the year received.¹

One point that surprises people: the still-working exception that delays RMDs from an employer plan does not extend to IRAs. If you are 74 and employed full-time, your traditional IRA RMD is still due on schedule. The same holds for your SEP and SIMPLE IRAs.

Employer-Sponsored Retirement Plans

The main workplace retirement accounts are all subject to RMDs: 401(k) plans in the private sector, 403(b) plans at nonprofits and public schools, and 457(b) deferred compensation plans for government employees. The underlying statute requires every qualified plan to include a distribution provision so that the account balance begins flowing out by the required beginning date.³

The Still-Working Exception

If you are still employed past the normal RMD starting age, you can delay withdrawals from your current employer’s plan until the year you actually retire. The exception has a firm limit: it does not apply if you own more than 5% of the business sponsoring the plan. Five-percent owners must begin RMDs based on age alone, regardless of employment status.¹

The exception also covers only the plan at your current employer. If you left a 401(k) or 403(b) behind at a previous job, that account’s RMD is due on the normal schedule.

Pre-1987 Balances in 403(b) Plans

A narrow rule applies to 403(b) accounts that hold pre-1987 contributions. If the plan has kept separate records for the pre-1987 portion, those dollars are not subject to the standard age-73 RMD rules. Distributions from the pre-1987 balance can be delayed until December 31 of the year you turn 75, or until April 1 after you retire, whichever comes later. If the plan failed to track pre-1987 amounts separately, the whole balance falls under the standard rules.¹

Roth Accounts

The original owner of a Roth IRA never has to take RMDs. Because Roth contributions are made with after-tax dollars and qualified growth is tax-free, the government has no deferred tax revenue to collect.⁴ You can leave a Roth IRA untouched for your entire life.

Roth accounts inside employer plans used to work differently. Before 2024, a designated Roth 401(k) or Roth 403(b) required distributions even though the account was funded with after-tax money. Section 325 of the SECURE 2.0 Act removed that requirement for tax years beginning after December 31, 2023, aligning employer Roth accounts with Roth IRAs.¹

The exemption ends at death. Anyone who inherits a Roth account is subject to distribution requirements, even though the distributions themselves remain tax-free. This trips up a lot of Roth owners who assume the “no RMD” feature carries through to their heirs.

Inherited Accounts

When a retirement account passes to a beneficiary, the account type matters less than the beneficiary’s relationship to the deceased. The SECURE Act of 2019 rewrote the inherited-account rules for deaths on or after January 1, 2020, and those rules apply across inherited traditional IRAs, inherited 401(k)s, and inherited Roth IRAs alike.

The 10-Year Rule

If you inherit a retirement account from someone who died after 2019 and you are not an “eligible designated beneficiary,” you must empty the account by December 31 of the year containing the 10th anniversary of the owner’s death.⁵

If the original owner had already reached their required beginning date, the IRS also expects annual distributions during the 10-year window. You cannot let the account sit for a decade and empty it at the end. Final regulations applying to calendar years beginning January 1, 2025, confirm that annual RMDs are required for designated beneficiaries in that situation, with the full balance still due by the end of year 10.⁶ If the owner died before their required beginning date, no annual distributions are required inside the 10-year window.

Eligible Designated Beneficiaries

A narrow group of beneficiaries can stretch distributions over their own life expectancy instead of following the 10-year rule:⁵

Surviving spouses, who have the most options and can generally roll the inherited account into their own IRA and follow standard age-based RMD rules.
Minor children of the deceased, who take life-expectancy distributions until they reach age 21, at which point the 10-year clock begins on the remaining balance.
Disabled or chronically ill individuals.
Beneficiaries not more than 10 years younger than the deceased.

Trusts as Beneficiaries

Naming a trust adds requirements. For the trust’s individual beneficiaries to be treated as designated beneficiaries for RMD purposes, the trust must be valid under state law, must be irrevocable (or become irrevocable at the owner’s death), must identify the individual beneficiaries from the trust document, and the trustee must provide the required documentation to the IRA custodian.⁷ A trust that fails these tests is treated as having no designated beneficiary, which usually accelerates the distribution timeline.

When RMDs Start

Knowing an account is subject to RMDs matters only when you reach the trigger age. The SECURE 2.0 Act set a two-step increase:⁸

Born before 1951: RMDs began at age 72.
Born 1951 through 1959: RMDs begin at age 73.
Born January 1, 1960, or later: RMDs begin at age 75, starting in 2033.

Your first RMD can be delayed until April 1 of the year after you reach the applicable age.⁹ Every subsequent RMD is due by December 31. Delaying the first one stacks two RMDs into the same calendar year, which can push you into a higher tax bracket and raise your Medicare premiums two years later, so most people take the first RMD in the year they reach the trigger age.

Aggregating Across Accounts

When you own more than one account subject to RMDs, whether you can pool them depends on the type. Traditional IRAs can be aggregated: calculate the RMD separately for each traditional IRA, then withdraw the total from whichever IRA you choose. The same flexibility applies to 403(b) accounts, which can be aggregated among themselves.¹⁰

Employer plans like 401(k)s and 457(b)s do not aggregate. Each plan’s RMD must be calculated and taken from that specific plan. You cannot satisfy a 401(k) RMD from your IRA, and you cannot satisfy one 401(k)’s RMD out of another 401(k) at a different former employer.¹⁰ Traditional IRAs and 403(b) plans also cannot be crossed: an IRA RMD must come from an IRA, and a 403(b) RMD must come from a 403(b). Anyone who has collected accounts at multiple employers over a career should map this out carefully before the first distribution year.

1
Internal Revenue Service. Retirement Plan and IRA Required Minimum Distributions FAQs
2
Office of the Law Revision Counsel. 26 USC 408 – Individual Retirement Accounts
3
Office of the Law Revision Counsel. 26 USC 401 – Qualified Pension, Profit-Sharing, and Stock Bonus Plans
4
eCFR. 26 CFR 1.408A-6 – Distributions
5
Internal Revenue Service. Retirement Topics – Beneficiary
6
Internal Revenue Service. Notice 2024-35, Certain Required Minimum Distributions for 2024
7
Internal Revenue Service. Publication 590-B (2025), Distributions from Individual Retirement Arrangements (IRAs)
8
Federal Register. Required Minimum Distributions
9
Internal Revenue Service. IRS Reminds Retirees: April 1 Final Day to Begin Required Withdrawals from IRAs and 401(k)s
10
Internal Revenue Service. RMD Comparison Chart (IRAs vs. Defined Contribution Plans)