A retiree turning 73 in 2025 logs into her brokerage account in October expecting to set up her first Required Minimum Distribution. Her custodian’s RMD-calculation tool tells her the minimum distribution amount is approximately 3.77% of her December 31, 2024 IRA balance. She remembers reading several articles in 2022 saying the RMD age had been raised to 72 by the original SECURE Act of 2019 and then to 73 by SECURE 2.0, but she also recalls coverage of proposals to raise the age further to 75. She isn’t sure whether the proposed 75 age applies to her, whether the new SECURE 2.0 penalty rules have actually taken effect, and whether the Uniform Lifetime Table percentage her custodian is using is current.
The Required Minimum Distribution rules have changed substantially over the past five years through three major pieces of legislation, the original SECURE Act of 2019, SECURE 2.0 (Division T of the Consolidated Appropriations Act, 2023), and various inflation-adjustment notices in between. Most retirement-content writing covers the high-level changes (the age raised from 70½ to 72 to 73 to eventually 75) but glosses over the operational specifics: which age applies to which birth-year cohort, what the actual current penalty for a missed RMD is, and which version of the Uniform Lifetime Table the custodian should be using. This article walks the current rules with the precision the topic requires.
The age-thresholds by birth year
The current RMD-commencement age depends on the taxpayer’s birth year, this is the part most articles oversimplify:
- Born before July 1, 1949: RMD age was 70½ (pre-SECURE Act). First RMD year was the year the taxpayer turned 70½.
- Born July 1, 1949 to December 31, 1950: RMD age was 72 (SECURE Act of 2019). First RMD year was the year the taxpayer turned 72.
- Born 1951 to 1959: RMD age is 73 (SECURE 2.0 §107). First RMD year is the year the taxpayer turns 73.
- Born 1960 or later: RMD age is 75 (SECURE 2.0 §107). First RMD year is the year the taxpayer turns 75.
The taxpayer turning 73 in 2025 falls in the 1951-1959 cohort. Her first RMD year is 2025; she can take her first RMD any time during 2025 or defer it (only) to April 1, 2026 (the “required beginning date” under IRC §401(a)(9)(C)). The second RMD is due by December 31, 2026.
The deferral to April 1 of the following year applies only to the first RMD. If she defers the 2025 RMD to early 2026, she will be taking two RMDs in calendar year 2026, pulling significant taxable income into one year. Most retirees take the first RMD in the year it’s due (2025 in her case) to avoid the doubling-up effect.
The penalty changes under SECURE 2.0
Before SECURE 2.0, the penalty for a missed RMD was a 50% excise tax on the under-distributed amount under IRC §4974, one of the harshest penalty rates in the entire Internal Revenue Code. The 50% rate was effectively a tripwire that penalized retirees, often elderly retirees, for administrative oversights that produced no tax-revenue cost.
SECURE 2.0 §302 reduced the rate to 25% effective for missed RMDs in 2023 and later. The rate further reduces to 10% if the missed RMD is corrected within the “correction window”, generally, by the end of the second calendar year following the year of the missed distribution. A retiree who misses a 2025 RMD has through December 31, 2027 to take the missed distribution, file Form 5329 reporting the under-distribution, and request abatement of the resulting 10% (or potentially 25%) penalty under reasonable cause.
The penalty change is operationally consequential. A retiree who discovers a missed RMD shortly after year-end now has a clear corrective procedure rather than facing the prior 50% tripwire. The right move on discovery is: take the missed amount immediately, file Form 5329 with the next return, and include the reasonable-cause statement that documents the oversight and the correction.
The Uniform Lifetime Table currently in use
The Uniform Lifetime Table is the divisor used to compute the RMD amount: account balance on December 31 of the prior year, divided by the table divisor for the taxpayer’s age in the current year, equals the minimum required distribution. The table was substantially revised in 2022 (Treas. Reg. §1.401(a)(9)-9, finalized November 2020 with effective date January 1, 2022) to reflect updated mortality data.
The 2022-and-later Uniform Lifetime Table produces lower required distributions than the pre-2022 table at every age. For a 73-year-old in 2025, the table divisor is 26.5, producing an RMD of approximately 3.77% of the prior-year-end balance. For comparison, the pre-2022 table for a 73-year-old produced a divisor of 24.7 and an RMD of approximately 4.05%. The change effectively reduces required distributions by 7-8% across the age range, allowing more deferred growth in the retirement account.
The custodian’s RMD-calculation tool should be using the post-2022 table. If the percentage seems materially higher than approximately 3.7% at age 73, 4.0% at age 75, 4.4% at age 78, 5.4% at age 82, or 8.8% at age 90, the tool may be using the pre-2022 table, confirm with the custodian.
What didn’t change: the categories of accounts subject to RMD
The RMD rules apply to traditional IRAs (including SEP-IRAs and SIMPLE IRAs), 401(k) plans, 403(b) plans, governmental 457(b) plans, and inherited Roth IRAs (under specific rules). Roth IRAs owned by the original account holder do not have RMD requirements during the owner’s lifetime, this is one of the structural advantages of Roth conversions for taxpayers who don’t need the distributions to fund retirement.
SECURE 2.0 §325 eliminated lifetime RMDs from Roth 401(k) accounts effective 2024, meaning Roth 401(k) accounts now match the no-RMD treatment of Roth IRAs during the owner’s lifetime. This is a substantive change that affects Roth 401(k) participants but was easy to miss in the broader SECURE 2.0 coverage.
The 10-year rule for inherited retirement accounts (other than spousal inheritance and certain exceptions) under SECURE Act §401 generally requires non-spouse beneficiaries to draw down inherited accounts within 10 years. SECURE 2.0 clarified, through Notice 2024-35 and Notice 2025-XX series, plus the final §401(a)(9) regulations, the interaction between the 10-year rule and the annual RMD requirement for non-eligible designated beneficiaries. The clarification matters for inherited-account planning but isn’t directly relevant to original-account-holder RMD calculations.
What didn’t change but almost did
SECURE 2.0 §107(c) includes scheduled future increases, the RMD age moves to 75 for taxpayers born 1960 or later, but the further proposed increases to 76, 77, or 78 that appeared in some legislative drafts did not make it into the final SECURE 2.0 text. Similarly, proposals to reduce the missed-RMD penalty rate to a flat 10% (eliminating the 25% intermediate rate) were not adopted. The current 25%-reducing-to-10%-on-correction structure stands.
What to do this year
Three practical points:
If you’re approaching the RMD age in your birth-year cohort, plan the first-year distribution timing carefully. Taking the first RMD in the year it’s due (rather than deferring to April 1 of the following year) avoids the doubled-up income year. Project the tax-bracket effect of the RMD before deciding.
If you have multiple retirement accounts, the RMD is computed separately for each, but with traditional IRAs, the total RMD across all traditional IRAs can be aggregated and taken from any combination of those accounts. 401(k) RMDs are not aggregable with IRA RMDs.
If you missed an RMD in a prior year and didn’t take corrective action, the 25%-reducing-to-10% rule is materially more favorable than the prior 50% penalty, take the missed distribution immediately, file Form 5329 with the current return, and request reasonable-cause abatement. The corrective procedure is documented in the Form 5329 instructions and works in the substantial majority of cases.
The RMD rules are knowable. The applicable age depends on birth year. The penalty for missing is reduced and correctable. The table the custodian should be using is the 2022 update. The structural complexity is real, but the operational rules are precise enough that an attentive retiree (or their advisor) can navigate them without surprises.
Authority: IRC §401(a)(9) (RMD rules generally); IRC §401(a)(9)(C) (required beginning date); IRC §4974 (missed-RMD excise tax); SECURE Act of 2019 (P.L. 116-94, first RMD-age increase to 72); SECURE 2.0 Act, Division T of Consolidated Appropriations Act 2023 (P.L. 117-328); SECURE 2.0 §107 (RMD age increases to 73 then 75); SECURE 2.0 §302 (penalty rate reduction to 25%/10%); SECURE 2.0 §325 (lifetime RMD elimination for Roth 401(k)); Treas. Reg. §1.401(a)(9)-9 (Uniform Lifetime Table, 2022 update); Form 5329 (Additional Taxes on Qualified Plans); Notice 2024-35 (10-year rule clarification); Pub 590-B (Distributions from Individual Retirement Arrangements); Pub 575 (Pension and Annuity Income).