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SECURE 2.0 (Public Law 117-328, signed December 2022) made more than 90 changes to retirement accounts, and the IRA-specific provisions are some of the most impactful for retirement planning. The biggest IRA changes now in effect in 2026 include the RMD age moving to 73 for savers born 1951-1959 and 75 for savers born 1960 or later, the RMD penalty dropping from 50% to 25% (or 10% if corrected in time), Roth 401(k) RMDs eliminated starting in 2024, Qualified Charitable Distribution limits now inflation-indexed with a $111,000 cap for 2026, a one-time $50,000 QCD to charitable remainder trusts or charitable gift annuities, Roth catch-up treatment for high earners, age 60-63 enhanced catch-up contributions, and 529-to-Roth IRA rollovers up to $35,000 lifetime .
SECURE 2.0 is a sprawling piece of legislation and most advisors still don’t have a complete map of what’s in it. Some provisions took effect immediately, some phased in over 2023, 2024, and 2025, and one or two important pieces are still being interpreted by the IRS through notice guidance . On top of that, the One Big Beautiful Bill Act (Public Law 119-21) signed in 2025 modified a few pieces of the SECURE 2.0 framework as of 2026 [3]. I keep a running checklist of what’s in force and what’s coming, and in this piece I want to lay that out for retirement-focused advisors who need to talk to clients in plain language about the current state of IRA rules.
The RMD age changes
SECURE 2.0 moved the Required Minimum Distribution starting age in two steps. The original SECURE Act of 2019 had already moved it from 70.5 to 72. SECURE 2.0 moved it again :
- Savers born 1950 or earlier had their RMD starting age set at 72 by the original SECURE Act and kept that age under SECURE 2.0.
- Savers born 1951 through 1959 have an RMD starting age of 73. Their first RMD is due by April 1 of the year after they turn 73.
- Savers born 1960 or later have an RMD starting age of 75. Their first RMD is due by April 1 of the year after they turn 75.
The gap year for savers born in 1960 is worth understanding. Somebody born in 1960 will reach age 65 in 2025 and age 75 in 2035. Their first RMD is due by April 1, 2036. That’s a full decade of planning runway compared to the pre-SECURE regime, and that runway is where Roth conversion planning delivers the most value.
For savers born in 1951, the first year of SECURE 2.0’s new 73 age, there was initial confusion about who had to take an RMD in 2023. IRS Notice 2023-54 clarified that savers who turned 72 in 2023 (born in 1951) did not have a 2023 RMD requirement and could delay to 2024 . That notice also provided rollover relief for RMDs that were taken under the pre-SECURE 2.0 rules and later found not to be required.
The RMD penalty reduction
Before SECURE 2.0, a missed RMD carried a 50% excise tax on the amount that should have been distributed but wasn’t. That was one of the harshest penalties in the tax code, and the IRS routinely granted waivers for savers who missed RMDs due to good-faith mistakes, but the statute on the books was 50% . SECURE 2.0 Section 302 reduced the penalty to 25% and added a two-year correction window during which the penalty drops further to 10% if the missed RMD is taken and properly reported .
The reduced penalty is a meaningful win for savers who discover a missed RMD, but it’s not a free pass. Advisors should still run RMD calculations precisely, document distributions carefully, and file Form 5329 when a correction is needed. The 10% correction rate applies only when the saver takes the missed distribution and files the proper correction within two years.
Roth 401(k) RMDs eliminated in 2024
Before SECURE 2.0, Roth balances inside a 401(k) or 403(b) plan were subject to lifetime RMDs at the RMD starting age even though Roth IRAs never were. Savers in the know would roll their Roth 401(k) balances into a Roth IRA before RMD age to escape the requirement. SECURE 2.0 Section 325 eliminated the lifetime RMD requirement for designated Roth accounts in employer plans starting in 2024 .
The practical effect is that a saver with a Roth 401(k) balance no longer has to do the Roth-IRA-rollover dance to avoid lifetime RMDs. The balance can stay in the employer plan and grow without required distributions, subject to the same RMD rules that applied to a Roth IRA already. This matters for savers with large Roth 401(k) balances who have reasons to keep them in the employer plan, including investment menu preferences, plan loan features, or creditor protection differences at the state level.
QCD inflation indexing and the $111,000 limit for 2026
Qualified Charitable Distributions from traditional IRAs to qualified public charities have been a core planning tool for charitably inclined retirees age 70.5 or older since 2006. A QCD satisfies the RMD for the year without the distribution counting as taxable income, which keeps AGI down and protects Social Security taxation and IRMAA bracket placement . The QCD limit was stuck at $100,000 per person for years. SECURE 2.0 indexed it to inflation starting in 2024 .
For 2026, the IRS-announced QCD limit is $111,000 per person . A married couple can each use their own $111,000 limit from their own IRAs for a combined $222,000 of annual charitable giving directly from retirement accounts without creating taxable income. For a couple well into RMD mode who are already giving meaningfully to charity, this is one of the highest-value moves in retirement tax planning.
The $50,000 one-time QCD to a CRT or CGA
SECURE 2.0 also created a one-time, once-in-a-lifetime option to direct up to $50,000 of QCD money to a Charitable Remainder Unitrust, Charitable Remainder Annuity Trust, or Charitable Gift Annuity instead of directly to a public charity . The $50,000 limit is also inflation-indexed going forward, and the 2026 amount is modestly higher than the original statutory figure.
The rules around the one-time QCD-to-CRT election are technical. The CRT must meet specific requirements under IRC Section 664, the donor can’t receive any benefit from the IRA other than the CRT income interest, the CRT can have only the donor and the donor’s spouse as income beneficiaries, and the election is a one-shot option. Done correctly, this creates a lifetime income stream from IRA dollars without a current-year tax hit, and it works well for donors who want to convert part of an IRA into a legacy vehicle.
Roth treatment for catch-up contributions
SECURE 2.0 Section 603 required catch-up contributions for high-income earners to be made as Roth contributions in 401(k), 403(b), and governmental 457(b) plans . The original statute set the effective date at 2024, but IRS Notice 2023-62 delayed implementation until 2026 because plan sponsors needed more time to update their systems [2]. Starting in 2026, any saver age 50 or older with wages above the statutory threshold (indexed for inflation) must make their catch-up contributions as Roth. The wage threshold is measured in the prior year and applies at the individual level.
The practical effect for high earners is that catch-up contributions they used to make on a pre-tax basis now have to be made post-tax. That’s a real tax cost in the contribution year, offset by the tax-free growth and distribution benefits of Roth treatment going forward. For savers who would have made the catch-up contribution pre-tax anyway, this is a mild negative. For savers who were already planning Roth contributions for diversification, this codifies what they were doing.
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Age 60 to 63 enhanced catch-up contributions
SECURE 2.0 Section 109 added an enhanced catch-up contribution for savers ages 60 through 63 in workplace retirement plans [1]. The enhanced limit is the greater of $10,000 or 150% of the regular catch-up amount, indexed for inflation. For 2025, the enhanced catch-up limit was $11,250, and the 2026 figure has been announced following the IRS annual release .
The enhanced catch-up applies only to the four-year window of ages 60, 61, 62, and 63. It’s a narrow benefit for savers in the final stretch before retirement, designed to give them one last push to boost qualified plan balances. Savers who can afford to max it out should, and advisors should flag the window for clients well in advance of their 60th birthday so the cash flow planning is in place.
The 529-to-Roth IRA rollover
SECURE 2.0 Section 126 created a new option to roll unused 529 plan balances into a Roth IRA for the designated beneficiary of the 529 account starting in 2024 . The rules are specific and worth knowing:
- Lifetime maximum of $35,000 per beneficiary.
- The 529 account must have been open for at least 15 years before the rollover.
- Contributions to the 529 within the last 5 years (and earnings on those contributions) are ineligible to roll over.
- Rollovers count against the annual Roth IRA contribution limit for the beneficiary in the year of the rollover.
- The beneficiary must have earned income at least equal to the rollover amount in the rollover year.
For families who over-funded a 529 because the kid got a scholarship or chose a cheaper school, this provision rescues some of the unused balance into a Roth IRA start for the child. It won’t make anyone wealthy on its own, but it’s a nice feature for exactly the kind of situation it’s designed to address.
Surviving spouse RMD elections
SECURE 2.0 Section 327 added an election for surviving spouses to be treated as the deceased spouse for RMD calculation purposes on an inherited IRA . When the surviving spouse is younger and the deceased spouse hadn’t yet reached their Required Beginning Date, electing this treatment can delay the start of RMDs until the deceased spouse would have reached RMD age. The election applies only to the inherited IRA and not to the surviving spouse’s own retirement accounts.
This is a narrow benefit, but for the right household it can delay taxable distributions by several years. Advisors handling post-death IRA planning for widows and widowers should run the numbers under both the standard treatment and the Section 327 election to see which produces a better after-tax result.
OBBBA modifications and interactions in 2026
The One Big Beautiful Bill Act in 2025 made several modifications to the broader retirement and tax framework that interact with SECURE 2.0 provisions . The senior deduction under OBBBA adds a new deduction for taxpayers age 65 or older, which changes the AGI-sensitivity calculus for Roth conversions and QCDs. The permanent $15 million estate tax exclusion under OBBBA affects the legacy planning incentive for large IRA conversions. The modified IRMAA bracket structure in 2026 raises the stakes on managing MAGI around the cliff thresholds, and QCDs remain one of the cleanest ways to satisfy RMDs without pushing MAGI up.
OBBBA did not repeal any SECURE 2.0 provisions outright, but it changed the planning context enough that any 2026 retirement plan should be run against the combined framework. Advisors using old worksheets from 2023 or 2024 should refresh before running client reviews this year.
The provision advisors most often mishandle is treating the 10-year rule as a one-time compliance box to check rather than a signal to start planning sooner. The SECURE Act showed that Congress can revisit the rules on IRA money, and this change opens the door for the next one. A Stonewood-ready advisor uses that opening to start the tax conversation now, modeling how a Roth conversion strategy today can help reduce exposure before the next round of changes arrives, rather than waiting until a client’s heirs are already working through the 10-year window.
Where to go from here
SECURE 2.0 [1] is dense, and the interactions with earlier SECURE provisions, OBBBA, and annual IRS guidance keep the planning picture moving. For the full breakdown of the 10-year rule and stretch IRA changes, read our [stretch IRA rules SECURE Act guide]. For the legacy planning implications of the new rules, see our [legacy IRA strategies deep dive]. For the broader picture of 2026 tax changes affecting retirees, read our [tax changes retirement 2026 overview]. And for a direct look at legislative risk factors retirement planners should be thinking about, see our [legislative risk retirement guide].
If you want to run SECURE 2.0 scenarios for a specific client household in software built for this kind of work, [schedule a Stonewood demo] and we’ll walk you through how our platform handles RMD sequencing, QCD planning, Stonewood’s software does not currently model QCD planning; confirm this reference should be reviewed before publishing.and Roth conversion timing under the current rules. You can also start by exploring [Roth Done Right software] for conversion planning specifically.
This article does not constitute tax, legal, or financial planning advice. Stonewood Financial is not a securities-licensed firm. Retirement account decisions should be made in consultation with a qualified tax advisor based on your specific situation.
Frequently Asked Questions
What is the RMD age under SECURE 2.0 in 2026?
Savers born 1951 through 1959 have an RMD starting age of 73. Savers born 1960 or later have an RMD starting age of 75. Savers born 1950 or earlier already started RMDs under the prior regime at age 72 .
What is the penalty for a missed RMD in 2026?>
The penalty is 25% of the missed RMD amount, reduced to 10% if the missed distribution is taken and properly reported within a two-year correction window . That’s down from the 50% pre-SECURE 2.0 penalty.
Can I roll a 529 into a Roth IRA under SECURE 2.0?>
Yes. Starting in 2024, unused 529 plan balances can be rolled into a Roth IRA for the designated beneficiary, subject to a $35,000 lifetime cap, a 15-year account age requirement, and annual Roth contribution limit matching .
What is the 2026 QCD limit?
The Qualified Charitable Distribution limit for 2026 is $111,000 per person, reflecting inflation indexing that started in 2024 under SECURE 2.0 . A married couple filing jointly can each use their own $111,000 limit from their own IRAs.
Do Roth 401(k) balances still have RMDs?
No. Starting in 2024, SECURE 2.0 eliminated the lifetime RMD requirement for designated Roth accounts in 401(k), 403(b), and similar employer plans . Roth 401(k) balances are now treated the same as Roth IRA balances for RMD purposes during the owner’s lifetime.
What is the age 60 to 63 enhanced catch-up contribution?
Savers ages 60, 61, 62, and 63 can make an enhanced catch-up contribution in workplace retirement plans equal to the greater of $10,000 or 150% of the regular catch-up amount, indexed for inflation. The 2025 enhanced amount was $11,250, and the 2026 figure is released in the IRS annual announcement .
Sources and References
Sources are numbered to match the inline [N] markers in the body above.
[1] SECURE 2.0 Act of 2022, Public Law 117-328 (December 2022), retirement provisions and effective dates. https://www.congress.gov/bill/117th-congress/house-bill/2617
[2] Internal Revenue Service, Notice 2023-54, guidance on SECURE 2.0 implementation and Roth catch-up delay. https://www.irs.gov/pub/irs-drop/n-23-54.pdf
[3] One Big Beautiful Bill Act, Public Law 119-21 (2025), senior deduction and estate exclusion provisions. https://www.congress.gov/
[4] Internal Revenue Code Section 401(a)(9), required minimum distribution rules. https://www.law.cornell.edu/uscode/text/26/401
[5] Internal Revenue Service, Publication 590-A and Publication 590-B, IRA contribution and distribution rules, with 2026 inflation-indexed figures. https://www.irs.gov/publications/p590a
About the Author
Tyler Randall is the National Sales Director at Stonewood Financial. He works with financial advisors across the United States helping them position annuities strategically in retirement plans. Over the past 15 years, he's coached advisors who have written over $400M in annuity premium. His approach focuses on consultative selling, data-driven positioning, and building client confidence through transparency. Tyler is a frequent speaker at industry conferences and webinars.
