SECURE 2.0 Act: Every RMD Change, Explained

The SECURE 2.0 Act — officially Division T of the Consolidated Appropriations Act, 2023 — was signed December 29, 2022, and contains 92 provisions affecting retirement accounts. Most are administrative details. Seven directly affect Required Minimum Distributions, and understanding them could save you tens of thousands in taxes over retirement.

This guide covers each provision by IRC section number, what changed, when it took effect, and who benefits.

SECURE 2.0 RMD Changes at a Glance

§ 107 — The New RMD Starting Ages

Before SECURE 2.0, anyone with a traditional IRA, 401(k), or other tax-deferred account had to begin RMDs at age 72. SECURE 2.0 changed this in two steps:

• Born 1951–1959: RMDs begin at age 73. The first RMD is due December 31 of the year you turn 73 — or you can delay to April 1 of the following year (the Required Beginning Date), though that stacks two distributions in one tax year.
• Born 1960 or later: RMDs begin at age 75. Effective January 1, 2033 (when the first 1960-born turn 73).¹

Why this matters for planning: Every additional year before RMDs is another year of the Roth conversion window. A retiree born in 1960 who retires at 62 has 13 years of low-bracket space to convert traditional IRA dollars to Roth — before the forced-distribution clock starts at 75. That window is roughly twice as long as what retirees had under the pre-SECURE rules starting at 70½.

§ 302 — Lower Penalty for Missed RMDs

The penalty for missing an RMD was 50% of the under-distribution under prior law — one of the harshest penalties in the tax code. SECURE 2.0 § 302 reduced this:

• Standard penalty: 25% of the amount you should have distributed but didn't (down from 50%).²
• Correction Window reduction: Take the missed distribution within two years of when it was due. The penalty drops to 10%.
• IRS waiver: The IRS can still waive the penalty entirely for a reasonable first-time mistake. File Form 5329 with a reasonable cause letter.

The practical effect: the old 50% penalty made missed RMDs financially devastating. At 25% — reducible to 10% with timely correction — the math still favors fixing the mistake immediately, but the punishment for a one-time error is no longer catastrophic.

§ 307 — QCD Limit Now Indexed for Inflation

Before SECURE 2.0, the Qualified Charitable Distribution limit was a fixed $100,000 per year — unchanged since QCDs were introduced in 2006. SECURE 2.0 § 307 indexed the limit for inflation starting in 2024.³

• 2024 limit: $105,000
• 2025 limit: $108,000
• 2026 limit: $111,000

SECURE 2.0 also introduced a one-time QCD to split-interest vehicles: a single distribution of up to $55,000 (2026, inflation-adjusted) from an IRA directly to a Charitable Remainder Unitrust (CRUT), Charitable Remainder Annuity Trust (CRAT), or Charitable Gift Annuity (CGA). This is a one-time lifetime election per taxpayer — the $55,000 counts toward (reduces) your $111,000 annual QCD limit for that year, so it doesn't create additional QCD room above $111,000.

See the QCD Calculator and QCD Rules Guide for the full mechanics.

§ 325 — No Lifetime RMDs from Roth Employer Plans

Roth IRAs have never had lifetime RMDs. But until 2024, Roth 401(k)s, Roth 403(b)s, and Roth 457(b)s did require distributions starting at the standard RMD age — a rule that undermined the point of tax-free Roth growth. SECURE 2.0 § 325 eliminated lifetime RMDs from Roth employer plan accounts effective January 1, 2024.⁴

Practical impact: If you have a Roth 401(k) balance at your employer — or rolled a Roth 401(k) into a Roth IRA — you no longer owe any lifetime RMDs on those funds. The accounts can compound tax-free indefinitely during your lifetime.

If you didn't roll over before 2024: Post-2023, you no longer need to roll Roth 401(k) balances into a Roth IRA to avoid RMDs. The in-plan Roth balance is exempt. For the plan year that began before January 1, 2024, some employers had already issued RMDs from Roth accounts — those cannot be put back.

• Roth 401(k): lifetime RMD eliminated starting 2024 ✓
• Roth 403(b): lifetime RMD eliminated starting 2024 ✓
• Roth 457(b): lifetime RMD eliminated starting 2024 ✓
• Roth IRA: always exempt ✓
• Roth SEP-IRA and Roth SIMPLE IRA (new account types allowed by SECURE 2.0 §601): exempt ✓

See Roth IRA and Roth 401(k) RMD Rules for the full breakdown including inherited Roth accounts (which do have the 10-year rule).

§ 327 — Surviving Spouse Election

Before SECURE 2.0, surviving spouses who inherited an IRA from a spouse had two options: (1) roll the inherited IRA into their own IRA and use their own age for RMD purposes, or (2) treat the inherited IRA as a beneficiary account and use the deceased spouse's age-at-death as the distribution baseline.

SECURE 2.0 § 327 added a third option effective 2024: the surviving spouse may elect to be treated as if they were the deceased spouse for RMD purposes. In practice, this means using the deceased spouse's birth year to determine the RMD start date — which matters when the deceased spouse was younger and had not yet reached RMD age.⁵

Example: Spouse A (born 1965, not yet at RMD age) dies in 2027. Spouse B (born 1958, already taking RMDs at 73) inherits. Under the § 327 election, Spouse B can treat the inherited account as if they are Spouse A — meaning RMDs on that balance don't start until 2040 (when Spouse A would have turned 75). This is a powerful deferral tool when the inheriting spouse is older than the deceased.

See Surviving Spouse IRA Options for all three paths and the tradeoffs.

§ 202 — Expanded QLAC Limits

A Qualified Longevity Annuity Contract (QLAC) lets you move a portion of your IRA balance into a deferred income annuity that starts payments at a later age (up to 85), removing that amount from the RMD calculation base during the deferral period. SECURE 2.0 made two improvements:⁶

• Dollar limit raised: From $145,000 to $200,000 at enactment, with annual inflation indexing. The 2026 limit is $210,000.
• 25% cap removed: Previously, the QLAC premium could not exceed 25% of your total IRA balance. That cap is eliminated. You can put the full $210,000 into a QLAC regardless of your account size.

At age 73 with a $1.5M IRA, a $210,000 QLAC reduces the RMD base to $1,290,000 — dropping the first-year RMD from ~$56,600 to ~$48,700. Over 10 years of deferral, the tax-deferred compounding inside the QLAC can be meaningful. See the QLAC Calculator for projected savings.

§ 126 — 529-to-Roth IRA Rollovers

This provision is most relevant to adult children of RMD-age parents, but can affect estate planning decisions around 529 accounts. Starting in 2024, unused 529 plan funds can be rolled to a Roth IRA tax-free, subject to these limits:⁷

• The 529 account must have been open for at least 15 years.
• Lifetime rollover limit: $35,000 per beneficiary.
• Annual rollover cap: the annual Roth IRA contribution limit ($7,500 in 2026; $8,600 if age 50+).⁷
• The rollover counts against the annual Roth contribution limit — so you cannot also make a separate Roth contribution in the same year up to the full limit.
• Contributions made in the last 5 years are not eligible to roll over.

For retirees with large 529 accounts (funded for grandchildren who received scholarships, or whose plans changed), this provides a way to redirect surplus education savings to retirement without income tax.

What SECURE 2.0 Did NOT Change

Several common misconceptions about SECURE 2.0:

• The SECURE 1.0 (2019) 10-year rule still applies. Non-spouse beneficiaries who inherit a traditional IRA must drain it within 10 years. SECURE 2.0 did not relax or extend this rule.
• Annual RMDs during the 10-year window are still required when the decedent was past RBD. T.D. 10001 (July 2024) confirmed this. SECURE 2.0 did not change it.
• The QCD mechanics are unchanged. Direct transfer from IRA custodian to charity is still required. A retiree taking the distribution and then writing a check doesn't qualify.
• The RMD calculation method is unchanged. Still December 31 prior-year balance ÷ IRS Uniform Lifetime Table divisor.
• Roth IRAs always had no lifetime RMDs. That's not a SECURE 2.0 benefit — it predates the law. SECURE 2.0 § 325 extended the same treatment to Roth employer accounts.
• The WEP/GPO repeal was NOT part of SECURE 2.0. That came later, in the Social Security Fairness Act (January 2025).

Planning Implications by Birth Cohort

Born 1951–1959 (RMD age 73): The two-year age extension from SECURE 1.0 (age 70½ → 72) and now SECURE 2.0 (72 → 73) together mean you have roughly 2.5 more years of Roth conversion window compared to pre-SECURE rules. For a $2M traditional IRA, two additional years at $150K/yr in conversions = $300K more in Roth — potentially $150K+ in lifetime tax savings.

Born 1960 or later (RMD age 75): An additional 2 years on top of the 73-age rule. The conversion window stretches even further. A 60-year-old who retires at 62 has 13 years before forced distributions begin. The planning implication is aggressive pre-RMD Roth conversion that can dramatically reduce the eventual RMD base.

Surviving spouses: The § 327 election adds a third path that can meaningfully defer forced distributions when the surviving spouse is older than the deceased. Evaluate all three options — rollover, beneficiary treatment, § 327 election — before defaulting to the spousal rollover.

Sources

1. IRS — Required Minimum Distributions: Age Table. SECURE 2.0 § 107: RMD age raised to 73 for born 1951–1959; age 75 for born 1960+.
2. IRC § 4974 — Excise Tax on Missed RMDs. SECURE 2.0 § 302 reduced the rate from 50% to 25%; 10% if corrected within two years.
3. IRS — 2026 Retirement Plan Limits. QCD limit for 2026: $111,000 (inflation-adjusted per SECURE 2.0 § 307).
4. IRS — Roth Comparison Chart. SECURE 2.0 § 325: Roth 401(k)/403(b)/457(b) lifetime RMDs eliminated starting January 1, 2024.
5. SECURE 2.0 Act § 327 — Surviving Spouse Election. Allows surviving spouse to use deceased spouse's age/birth year for RMD timing.
6. IRS Notice 2025-67 — 2026 QLAC Limit. 2026 QLAC limit: $210,000 (inflation-indexed from SECURE 2.0 § 202 base of $200,000). 25% cap removed.
7. IRS — 529 Rollovers to Roth IRAs. SECURE 2.0 § 126: 15-year seasoning requirement, $35K lifetime cap, annual Roth contribution limit applies.

Tax values and section references verified against IRS publications, law.cornell.edu, and IRS Notice 2025-67 as of June 2026. SECURE 2.0 was enacted December 29, 2022, as Division T of the Consolidated Appropriations Act, 2023 (Pub. L. 117-328).