Required Minimum Distributions and QCDs: Your December 31, 2026 Checklist

If you’re 73 or older and you have money in a traditional IRA or 401(k), it’s time to start paying the piper. This is the point where required minimum distributions (RMDs) kick in: you have to take a minimum amount out each year, and that withdrawal is generally taxable income.

The rules aren’t complicated once you see them laid out, but the details matter: which year you start, which accounts can be combined, what happens if you miss one. And for anyone who gives to charity, there’s a strategy that can turn some or all of that required withdrawal into a tax-free gift. That strategy, the qualified charitable distribution, gets its own section below.

With December 31 roughly eight weeks away as of this post, now is the time to check where you stand. Custodians get busy in December, and “I submitted the request on December 29” isn’t a plan.

As always, this is general information and hasn’t been customized for your situation. If you’d like a recommendation for your specific accounts, feel free to schedule a consultation.

Who Has to Take an RMD (and When It Starts)

The SECURE 2.0 Act raised the age when RMDs begin, and it’s tied to your birth year:

Born 1951 through 1959: RMDs begin at age 73
Born 1960 or later: RMDs begin at age 75

So if you were born in 1953, you turn 73 in 2026, and 2026 is your first RMD year.

RMDs apply to traditional IRAs, SEP IRAs, SIMPLE IRAs, and employer plans like 401(k)s, 403(b)s, and 457(b)s. They don’t apply to Roth IRAs during the original owner’s lifetime. And as of 2024, they no longer apply to Roth 401(k)s or Roth 403(b)s either, which used to be an annoying exception that pushed people to roll Roth plan money into a Roth IRA just to avoid it.

If you’ve inherited an IRA, different rules apply, including the 10-year rule for most non-spouse beneficiaries. That’s a separate topic, and I covered it in detail in Inherited IRA: What the 10-Year Rule Means for You.

The Deadlines: December 31, With One Exception

Your RMD for each year is due by December 31 of that year. The one exception is your very first RMD, which you can delay until April 1 of the following year.

That sounds like a gift, and sometimes it is. But there’s a catch: delaying the first RMD doesn’t delay the second one. If you push your 2026 RMD to April 1, 2027, you still owe your 2027 RMD by December 31, 2027. That means two taxable withdrawals in the same tax year.

Let’s say Linda was born in 1953 and turns 73 in 2026. Her first RMD is about $15,000. If she takes it in December 2026, it’s 2026 income. If she waits until March 2027, both her 2026 and 2027 RMDs (roughly $30,000 combined) land on her 2027 return. Depending on her other income, that bunching could push more of her Social Security into taxable territory, bump her into a higher bracket, or raise her Medicare premiums two years later.

Delaying can make sense if your income will be noticeably lower next year, for example if you retired partway through 2026. For most people, taking the first RMD in the year you turn 73 keeps things simpler and smoother.

How Your RMD Is Calculated

The math is simpler than people expect:

Your account balance on December 31 of last year ÷ your life expectancy factor = this year’s RMD

The life expectancy factor comes from the IRS Uniform Lifetime Table in Publication 590-B. A few examples:

Age in 2026	Factor
73	26.5
75	24.6
80	20.2

If you’re 73 and your IRA was worth $400,000 on December 31, 2025, your 2026 RMD is $400,000 ÷ 26.5, or about $15,094.

Two notes. First, if your spouse is more than 10 years younger than you and is the sole beneficiary of the account, you use a different table (the Joint Life and Last Survivor table), which produces a smaller RMD. Second, your custodian will usually calculate the number for you, but it’s worth checking. Custodians don’t always know about every account you hold elsewhere, and they won’t know if your beneficiary situation qualifies for the joint table.

Which Accounts Can Be Combined

This is where people trip up, because the rules depend on the account type:

IRAs (traditional, SEP, SIMPLE): You calculate the RMD for each IRA separately, but you can add them up and take the total from any one IRA, or any combination.
403(b)s: Same idea. Calculate each, take the total from any of them.
401(k)s and 457(b)s: Each plan must satisfy its own RMD. You can’t take your 401(k) RMD out of your IRA, or vice versa.
Inherited IRAs: These only combine with other IRAs inherited from the same person.

Let’s say Tom has two traditional IRAs and an old 401(k) from a previous employer. He can pull his combined IRA RMD from whichever IRA he prefers, maybe the one with cash sitting in it so he doesn’t have to sell investments. But the 401(k) has to cough up its own RMD separately. If Tom doesn’t need multiple accounts, consolidating the old 401(k) into an IRA before RMDs start can simplify life considerably.

The Still-Working Exception

If you’re still working past your RMD age and participate in your current employer’s retirement plan, you can generally delay RMDs from that plan until April 1 after the year you retire. Two limits: it doesn’t apply if you own more than 5% of the business, and it never applies to IRAs. Your IRAs still require RMDs on the normal schedule, even if you’re working full time.

What Happens If You Miss One

The penalty used to be a jaw-dropping 50% of the amount you failed to withdraw. SECURE 2.0 reduced it to 25%, and to 10% if you correct the mistake within the correction window (generally by the end of the second year after the missed RMD, and before the IRS assesses the penalty).

If you miss an RMD, take the missed amount out as soon as you notice, and file Form 5329 with your return. If the shortfall was due to a reasonable error, such as a custodian mistake or a serious illness, you can request a waiver of the penalty entirely by attaching an explanation. The IRS has historically been fairly reasonable about this when the missed amount is promptly made up.

Qualified Charitable Distributions: The RMD Strategy for People Who Give

If you give to charity anyway, a qualified charitable distribution (QCD) may be the most tax-efficient way to do it, and it works hand in hand with RMDs.

A QCD is a transfer directly from your IRA to a qualified charity. The money never touches your bank account. Here’s why that matters:

It counts toward your RMD. A QCD satisfies all or part of your required distribution for the year.
It’s excluded from your income. Unlike a regular IRA withdrawal, a QCD doesn’t show up in your adjusted gross income (AGI).
You don’t have to itemize. The benefit comes from the income exclusion, not a deduction, so it works even if you take the standard deduction.

QCD Rules for 2026

Age: You must be at least 70½ on the date of the transfer. Note that this is earlier than RMD age. You can start making QCDs a few years before RMDs kick in.
Annual limit: Up to $111,000 per person for 2026 (the limit is now indexed for inflation). A married couple can each give up to that amount from their own IRAs.
Eligible accounts: IRAs, including inherited IRAs. Not 401(k)s or 403(b)s. If your money is in a 401(k), you’d need to roll it to an IRA first. SEP and SIMPLE IRAs only qualify if the employer isn’t still contributing to them.
Eligible charities: Public charities, like churches, food shelves, schools, and most nonprofits you’d recognize. Donor-advised funds, private foundations, and supporting organizations don’t qualify.
Direct transfer: The custodian sends the money to the charity, or issues a check payable to the charity. If the check is made out to you, it’s a regular taxable distribution, not a QCD.
No double benefit: Because the QCD is already excluded from income, you can’t also claim it as a charitable deduction.

Why a QCD Often Beats Giving Cash

Under the new charitable rules for 2026, non-itemizers can deduct up to $1,000 of cash gifts ($2,000 for married couples filing jointly). That’s a real improvement, but a QCD is often still better for retirees, for a few reasons:

There’s no cap that small. A QCD can exclude up to $111,000. The non-itemizer deduction tops out at $1,000/$2,000.
It lowers your AGI, not just your taxable income. That’s important because AGI drives a lot of other things in retirement: how much of your Social Security is taxable, whether you pay Medicare IRMAA surcharges, and other income-based thresholds. A deduction reduces taxable income, but only an exclusion keeps the money out of AGI in the first place.
Minnesota follows along. Because a QCD never shows up in your federal AGI, it stays out of your Minnesota income as well.

Let’s say Margaret is 76, takes the standard deduction, and has a $20,000 RMD for 2026. She gives about $6,000 a year to her church and a local food shelf. If she takes the full $20,000 RMD and writes checks to the charities, all $20,000 is in her AGI, and she can deduct up to $1,000 of the cash gifts under the new non-itemizer rule. If she instead directs $6,000 as QCDs and takes the remaining $14,000 as a regular distribution, her AGI is $6,000 lower, her full RMD is still satisfied, and the charities receive exactly the same amount.

QCD Mistakes to Avoid

Do the QCD first. The first dollars out of your IRA each year count toward your RMD. If you take your full RMD in March and make a QCD in December, the QCD is still excluded from income, but it can’t retroactively undo the taxable RMD you already took. If you plan to use QCDs, schedule them early in the year, or at least before you take your regular distribution.
Watch the December deadline. The QCD must be completed by December 31. If your custodian mails a check to the charity, allow plenty of time. Starting in early December is reasonable. Starting December 28 is not.
Get the acknowledgment. You need a written acknowledgment from the charity, the same as you would for a deductible gift, confirming the amount and that you didn’t receive anything in return.
Tell your tax preparer. Your Form 1099-R will show the distribution from your IRA. Depending on your custodian, it may not clearly identify which portion was a QCD. It’s your responsibility, and your preparer’s, to report the QCD correctly so it’s excluded from income. Keep the charity acknowledgments with your tax documents.
Watch for post-70½ IRA contributions. If you’ve made deductible traditional IRA contributions after age 70½ (allowed since 2020), those contributions reduce the amount of your QCDs that can be excluded. This is an anti-abuse rule, and it surprises people who are still working and contributing.

A Few Planning Angles

Use your RMD to cover your taxes. You can have federal (and Minnesota) income tax withheld from your RMD. Here’s a lesser-known benefit: withholding is treated as if it were paid evenly throughout the year, no matter when it actually happens. If you took a large IRA withdrawal early in the year or sold investments at a gain, a December RMD with extra withholding can help cover any shortfall without triggering an underpayment penalty, something a late estimated payment can’t do.

Consider Roth conversions before RMDs start. The years between retirement and RMD age often have lower income. Converting some traditional IRA money to a Roth during those years means paying tax now, at potentially lower rates, in exchange for smaller RMDs later. This doesn’t work for everyone, but it’s worth running the numbers if you’re in that window.

Think about IRMAA two years out. Medicare Part B and Part D premiums are based on your income from two years earlier. A large RMD or a bunched first-year RMD in 2026 shows up in your 2028 Medicare premiums. QCDs and careful timing can help keep you under the thresholds.

Your December 31 Checklist

Confirm your RMD amount for every account, especially if you have accounts at more than one custodian.
Check which accounts can be combined and which need their own distribution.
If you give to charity and you’re 70½ or older, set up QCDs before taking your regular distribution.
Decide on withholding for the distribution, federal and Minnesota.
Submit requests early in December so the custodian has time to process them.
If this is your first RMD, decide whether to take it by December 31 or delay to April 1, and understand the two-RMD tradeoff if you delay.
Keep your QCD acknowledgments and give them to your tax preparer with your 1099-R.

Questions About Your RMD?

RMDs are one of those areas where small details, like which account to draw from or whether to delay the first one, can change your tax bill more than you’d expect. For a quick refresher, my Tax Tuesday video on RMDs covers the basics. If you’d like help coordinating your RMDs, QCDs, and withholding for 2026, reach out or schedule a consultation and we can look at your accounts together before the deadline.

The information in this post is general in nature and hasn’t been customized for your specific tax situation. RMD and QCD rules depend on your birth year, account types, beneficiaries, and other income. For personalized advice regarding your retirement distributions, please schedule a consultation.