IRS Defers Proposed Regulation RMD Requirements by at Least One Year, Provides Temporary Rollover Relief to those Born in 1951

Advance version of Notice 2023-54 [PDF 141 KB] providing transition relief for plan administrators, payors, plan participants, individual retirement account and annuity (IRA) owners, and beneficiaries in connection with the change in the required beginning date for required minimum distributions (RMDs) under section 401(a)(9) pursuant to section 107 under Division T of the Consolidated Appropriations Act, 2023, titled “SECURE 2.0 Act of 2022” (SECURE 2.0 Act).

Notice 2023-54 also:

  • Provides guidance related to certain specified RMDs for 2023
  • Announces that the final regulations that the U.S. Treasury Department and the IRS intend to issue related to RMDs will apply for purposes of determining RMDs for calendar years beginning no earlier than 2024


Section 107 of the SECURE 2.0 Act amended section 401(a)(9)(C) to delay the required beginning date applicable to section 401(a) plans and other eligible retirement plans described in section 402(c)(8), including IRAs.

  • For an IRA owner who attains age 72 after December 31, 2022, and age 73 before January 1, 2033, the new required beginning date (that is, the date by which RMDs must begin) is April 1 of the calendar year following the calendar year in which the individual attains age 73, rather than April 1 of the calendar year following the calendar year in which the individual attains age 72.
  • This amendment to section 401(a)(9)(C) is effective for distributions required to be made after December 31, 2022, with respect to individuals who will attain age 72 after that date.
  • As a result of this amendment, IRA owners who will attain age 72 in 2023 (that is, individuals born in 1951) will have a required beginning date of April 1, 2025, rather than April 1, 2024. This delay in the required beginning date means that these IRA owners (who, prior to enactment of the SECURE 2.0 Act, would have been required to take minimum distributions from their IRAs for 2023) will have no RMD due from their IRAs for 2023.