Year-End RMD Checklist: 8 Things to Do Before December 31

December 31 is the hard deadline for most RMD actions. Miss it and the IRS charges 25% of the under-distribution — and several planning opportunities (like QCDs and Roth conversions) simply expire for the tax year. This checklist covers the eight things every retiree with tax-deferred accounts should address before year-end.

1. Confirm your total RMD across all accounts

Your RMD is account-balance-at-end-of-prior-year ÷ your IRS life-expectancy divisor.¹ Before December 31, verify:

• IRAs aggregate. All traditional IRAs (including SEP-IRAs and SIMPLE IRAs) pool together — you calculate one combined RMD and can take it all from a single account. (How aggregation works →)
• 401(k)s do not aggregate. Each 401(k) plan requires its own separate distribution. Old employer plans owe RMDs even if you're still working at a different employer. (401(k) RMD rules →)
• 403(b)s have their own pool. 403(b) accounts aggregate with each other, separately from IRAs and 401(k)s. Pre-1987 balances may be exempt entirely. (403(b) rules →)
• 457(b) plans are also a separate pool — neither IRA nor 401(k). (457(b) rules →)

Use the RMD Calculator to confirm your current-year amount and see 10-year projections.

2. First-year decision: take by December 31 or delay to April 1?

This step applies only in the year you turn 73 (or 75 if born 1960+). Skip it if you've been taking RMDs for more than one year.

If 2026 is your first RMD year, you have a one-time option: delay your first RMD until April 1, 2027.¹ But this creates a double-RMD year — you'd owe both your 2026 RMD (by April 1) and your 2027 RMD (by December 31) in the same calendar year.

The April 1 option does not extend to QCDs (see step 4 below) — and if you plan to use QCDs to offset your first RMD, you must take the QCD by December 31 regardless.

3. Check your custodian's internal processing cutoff

The IRS deadline is December 31, but your custodian's internal cutoff is earlier. Most major custodians require distribution requests 5–15 business days before December 31 to guarantee same-year processing. A few accept requests through December 29–30 for electronic transfers, but mail-based requests typically need to arrive by early-to-mid December.

Call your custodian by mid-November if you haven't already confirmed this year's RMD is on track. If your custodian runs automatic RMD distributions, verify the scheduled amount matches your calculation — custodians can use prior-year account values or incorrect ages if their records aren't current.

4. Complete all QCDs before December 31 — no exceptions

If you're 70½ or older and plan to use Qualified Charitable Distributions (QCDs) to offset your RMD, those must be complete by December 31.² Unlike your first-year RMD, there is no April 1 extension for QCDs.

• 2026 QCD limit: $111,000 per person ($222,000 for married couples each making QCDs from separate IRAs).²
• A QCD counts toward your RMD but is excluded from your adjusted gross income — so it doesn't add to Social Security provisional income, push you past IRMAA thresholds, or inflate your taxable income the way a standard withdrawal would.
• The check (or direct transfer) must arrive at the charity by December 31. A check mailed December 30 that arrives January 3 does not count for 2026.
• One-time QCD to a split-interest vehicle (charitable remainder trust or charitable gift annuity): the 2026 limit is $55,000 per person — a one-time election.²

Use the QCD Calculator to see the tax savings and IRMAA tier impact before finalizing the amount. Full strategy details: QCD Rules & Strategy Guide →

5. Use year-end lump-sum withholding to cover your tax bill

Federal and state income taxes on RMDs don't withhold automatically at the correct rate — the default is just 10%, which is often not enough for retirees in the 22–24% bracket. But there's a powerful year-end fix:

The December lump-sum withholding strategy: IRS Publication 505 specifies that taxes withheld from any retirement distribution are treated as if paid ratably throughout the year — not just in December.³ This means if you've been underpaying estimated taxes all year, you can take a December distribution with a high withholding election (up to 100%) and have it credited as though you'd paid it evenly in April, June, September, and January. This eliminates underpayment penalties.

How to execute it with Form W-4R:

• Request a supplemental distribution in December (in addition to any earlier RMDs you already took)
• Complete Form W-4R electing withholding above the 10% default — you can elect any rate from 0% to 99%
• Submit the form to your custodian before their December processing cutoff

Full details and estimated tax safe harbor rules: RMD Tax Withholding Guide →

6. Satisfy your full RMD before any Roth conversion

If you want to convert additional IRA funds to Roth before year-end, the ordering rule in IRC §408(d)(3)(E) requires that the RMD comes out first — the first dollars distributed from a traditional IRA in any year are automatically deemed to satisfy the RMD.¹ RMD dollars cannot be converted to Roth; only amounts above the RMD are eligible.

Practical sequence:

1. Confirm your full RMD amount across all accounts
2. Take any remaining RMD not yet withdrawn for the year
3. Then execute any Roth conversion on the portion above the RMD

The Roth conversion itself must also be complete by December 31 to count for the 2026 tax year — there's no extension. Use the Roth Conversion Sizing Calculator to find the bracket-filling amount given your RMD income, IRMAA constraints, and any other 2026 income. Full post-RMD conversion strategy: Roth Conversions After 73 →

7. Check inherited IRA annual RMD deadlines

If you inherited a traditional IRA from someone who had already passed their Required Beginning Date (RBD — typically April 1 of the year after they turned 73), the final T.D. 10001 regulations require you to take annual distributions every year of the 10-year window, not just drain the account by Year 10.⁴ These annual RMDs are calculated using your single life expectancy and also have a December 31 deadline each year.

The IRS waived penalties for missed inherited IRA annual RMDs for tax years 2021–2024, but that relief period has ended. Inherited IRA annual distributions for 2025 and 2026 are required.

Inherited IRA RMDs do not aggregate with your own IRA RMDs — they are calculated and distributed separately. Full rules and a distribution optimizer: Inherited IRA 10-Year Rule Calculator →

8. Review your IRMAA exposure for two years out

Medicare Part B and Part D premium surcharges (IRMAA) use your MAGI from two years prior. Your 2026 income determines Medicare premiums starting January 2028.⁵ As you approach year-end, consider:

• Are you near an IRMAA cliff? Even $1 of additional income can trigger the next surcharge tier — worth $600–$4,000+ per year per person in extra Medicare premiums.
• Did a large RMD, Roth conversion, or capital gain sale push you into the next tier unexpectedly? The IRMAA Life-Changing Event (LCE) appeal process lets you reduce surcharges based on current income if you've had a qualifying event (retirement, divorce, death of spouse, loss of income). File SSA Form SSA-44.
• For 2026, the first IRMAA threshold for Medicare Part B is $106,000 (single) / $212,000 (MFJ).⁵

Full tier structure and planning strategies: IRMAA Planning Guide →

Bonus: December 31 beneficiary account split deadline

If you inherited an IRA this calendar year and there are multiple beneficiaries named on the account, December 31 is the deadline to split the inherited IRA into separate accounts — one per beneficiary. Splitting by this date allows each beneficiary to use their own life expectancy for RMD calculations (for EDB beneficiaries) or to start their own independent 10-year clock. Missing this deadline means all beneficiaries are subject to the shortest remaining life expectancy of the group.¹

Full strategy: IRA Beneficiary Designation Guide →

Summary: December 31 vs April 1