RMD Deadline Traps: The December 31 and April 1 Rules

A required minimum distribution (RMD) is the least amount the IRS requires you to take out of most tax-deferred retirement accounts each year once you reach a certain age. The rules look simple, yet the dates catch people out. This guide covers the deadlines, the first-year option that creates two RMDs in one year, and what the IRS says happens if one is missed. It is general education, not tax advice. A tax professional can apply the rules to your accounts.

When is a required minimum distribution due each year?

For every year after your first, the IRS says you must take your RMD by December 31. In its words: "For each year after your required beginning date, you must withdraw your RMD by December 31" (IRS, Retirement topics - RMDs).

The amount is worked out from your account balance. The IRS FAQ says the RMD is calculated by "dividing the prior December 31 balance" of the IRA or plan account by a life expectancy factor from the tables in IRS Publication 590-B (IRS RMD FAQs). You can estimate the figure with our RMD calculator and read how the calculation works in our Gold IRA RMD guide.

When does the first RMD have to start?

The starting age depends on when you were born. The statute sets an "applicable age" in 26 U.S.C. 401(a)(9)(C)(v):

Source: 26 U.S.C. 401(a)(9)(C)(v).

Working through those dates (our arithmetic), the first test covers people born from 1951 through 1959 and the second covers people born in 1959 or later. So the statute's wording for someone born in 1959 appears in both ranges. We did not open IRS guidance that settles that year, so if you were born in 1959, ask your custodian or a tax professional which age they apply. The IRS pages we opened describe 73 as the general starting age and do not give a birth-year table.

What is the April 1 rule for the first RMD?

Your first RMD is due for the year you reach the applicable age. The IRS FAQ says you "can delay taking the first RMD until April 1 of the following year" (IRS RMD FAQs). For IRAs the IRS calls this date your required beginning date: April 1 of the year after you reach the applicable age.

The delay is optional. It does not cancel the next RMD. The IRS FAQ gives this example: a person who reaches age 73 in 2024 must take the first RMD by April 1, 2025, and the second by December 31, 2025.

A worked example

Say a person reaches age 73 in 2026. The table shows the two choices.

This is our illustration built from the IRS timeline. The IRS pages we opened do not discuss how the extra withdrawal affects a tax bill. A tax professional can explain how two withdrawals landing in one calendar year may change your return.

What happens if you miss an RMD?

The IRS says the amount you did not take may be "subject to an excise tax of 25%, 10% if the RMD is timely corrected within two years" (IRS RMD FAQs). An excise tax is a separate tax on a specific action or omission. It is in addition to the ordinary income tax on any distribution.

The FAQ adds that you should file Form 5329 with the tax return for the year the full RMD was required but not taken. The IRS says the penalty may be waived if you show the shortfall was due to reasonable error. You request the waiver on Form 5329 and attach a letter of explanation. Whether a waiver is granted is the IRS's decision.

Which common mistakes affect the deadline?

• Rolling the RMD over. The IRS FAQ answers "No" to whether RMD amounts can be rolled over into another tax-deferred account.
• Carrying an extra withdrawal forward. Asked whether a distribution larger than one year's RMD can count toward a future year, the IRS answers "No."
• Assuming the custodian handles it. The FAQ says the custodian or plan administrator may calculate the RMD, but "the account owner is ultimately responsible for taking the correct RMD amount."
• Mixing up account types. IRAs are calculated separately but the total can be taken from one or more of them. For 401(k) and 457(b) plans, RMDs must be taken separately from each plan.
• Expecting a Roth IRA to follow the same rule. The IRS says you are not required to take withdrawals from Roth IRAs, or from designated Roth accounts in a 401(k) or 403(b) plan, while the owner is alive.

Does still working change the first deadline?

Sometimes, but not for IRAs. For employer plans such as a 401(k), the statute's required beginning date can depend on the year the employee retires. That retirement-year option does not apply to IRAs under 408(a)(6) or (b)(3) (26 U.S.C. 401(a)(9)(C)). The IRS also says a plan document may require distributions to begin after the starting age even if you are still employed, and that delaying until retirement is possible only "if your plan allows" it (IRS, Retirement topics - RMDs). The IRS FAQ also notes this delay does not apply to 5% owners of the business. Check your plan's rules.

How does this apply to a Gold IRA?

A Traditional IRA that holds gold or silver follows the same deadlines as any Traditional IRA. The calendar does not change because of the metal. What can differ is practical: the RMD must be met by a distribution, so owners with most of their IRA in physical metal need to think ahead about how the amount will be paid. Our Gold IRA RMD guide covers cash and in-kind options. Selling or shipping metal can involve fees and risks that vary by custodian, so ask yours for its process and timing well before December 31. This section is general information, not a recommendation.

Related questions

• How does the age-60-to-63 catch-up differ from RMD rules? See super catch-up at ages 60 to 63.
• How does your retirement date affect when you start withdrawals? See choosing a retirement date.
• Where does this fit in the bigger picture? See our retirement planning guide and the Gold IRA overview.

What we did not check

The IRS Publication 590-B and Form 5329 instructions did not open during research, so the life expectancy tables and exact form line instructions are not covered here. Rely on those documents or a tax professional for them.