On December 18, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Announcement 2025-2. In this Announcement, the Treasury and IRS state that they anticipate certain provisions of future final regulations relating to required minimum distributions (RMDs) will apply beginning in the 2026 distribution calendar year. This delayed applicability date is one year later than previously stated in the proposed RMD regulations issued on July 18, 2024¹ (the “2024 proposed RMD regulations”). Provisions of the 2024 proposed RMD regulations not impacted by this Announcement will generally apply for calendar years beginning on or after January 1, 2025, the same applicability date as the related provisions in the concurrently issued 2024 final RMD regulations.²

The delayed applicability date is in response to comments the IRS received on certain provisions of the 2024 proposed RMD regulations raising issues and concerns about the foreseen difficulties of implementing many of the changes on time if the original January 1, 2025, applicability date were to remain in the eventual final regulations. The concerns include uncertainties in the timing of when the issues that were raised might be resolved and when the final regulations might be issued.

The specific provisions of the 2024 proposed RMD regulations that, once finalized, are anticipated to apply beginning in the 2026 distribution calendar year are the amendments to Regulation §§1.401(a)(9)-4, 1.401(a)(9)-5, and to 1.401(a)(9)-6,³ which include the following:

• DC plans: surviving spouse elections for RMDs. This provision relates to surviving spouse elections in defined contribution (DC) plans. It allows the surviving spouse to be treated as the participant for RMD purposes, outlines the rules for continued RMDs to the spouse’s beneficiary after the spouse’s death, and specifies the timing of the final payment to the spouse’s beneficiary.
• DC plans: aggregation option for annuity contracts.⁴ This provision relates to the timing and method for determining the fair market value of an annuity contract purchased with a portion of a participant’s DC plan account balance under the aggregation option.
• DC plans: RMDs from designated Roth accounts. This provision relates to distributions from designated Roth accounts not counting toward satisfying the RMD requirement during the participant’s lifetime for any year a participant is required to take an RMD.
• DC and DB plans: corrective distributions and excise tax reduction. This provision relates to corrective distributions for missed RMDs from DC plans and defined benefit (DB) plans in prior years not counting as RMDs in the year the corrective distribution is made.

Provisions from the 2024 proposed RMD regulations that are not expected to have a delayed applicability date include:

• The clarification that the definition of applicable age is 73 for individuals born in 1959 for determining the required beginning date for RMDs
• Special RMD rules for beneficiaries of a see-through trust
• Updated uniform lifetime table
• Determining the portion of a distribution that is not an RMD that is eligible for rollover (such as a distribution from a designated Roth account)

For periods before the applicability date of these amendments, a reasonable, good-faith interpretation of the statutory provisions underlying the amendments must be applied.

Please contact your Milliman consultant with any questions about how these RMD changes may impact your plan(s).

¹ On July 18, 2024, the Treasury and the IRS issued both: (1) final regulations to update the RMD rules, and (2) proposed RMD regulations for changes not addressed in the final regulations. Both the 2024 final and proposed RMD regulations were published in the Federal Register on July 19, 2024. Announcement 2025-2 relates to certain provisions of the 2024 proposed RMD regulations. Our bulletin summarizing the 2024 proposed RMD regulations can be found at: https://www.milliman.com/en/insight/irs-proposed-regulations-rmd.

² Our bulletin summarizing the 2024 final RMD regulations can be found at: https://www.milliman.com/en/insight/irs-final-rmd-regulation-secure-act.

³ This provision of the 2024 proposed regulations will apply in very few situations, specifically in the case of the division of joint and survivor benefits under a qualifying longevity annuity contract (QLAC) post-divorce, occurring after the purchase of the QLAC but before the commencement of annuity payments, clarifying that, for a plan that is not subject to the qualified domestic relations order (QDRO) rules of the Internal Revenue Code and ERISA (e.g., governmental plans, church plans, and 457(b) plans), a separation agreement or divorce decree is acceptable for such division in lieu of a QDRO.

⁴ The 2024 proposed regulations indicate that the prescribed method for determining the fair market value of the annuity contract is set to apply “beginning with the determination used for the 2026 distribution calendar year.” Thus, this portion of the provision is unaffected by the delayed applicability date.