SECURE Act 2.0 and Inherited IRAs: What Changed for Beneficiaries

Three changes from 2022 that directly affect how inherited IRA beneficiaries calculate and plan their distributions — with worked examples.

What is SECURE Act 2.0?

The SECURE Act 2.0 — formally Division T of the Consolidated Appropriations Act, 2023 — was signed into law on December 29, 2022.¹ It is a companion law to the original SECURE Act of 2019, not a replacement. The 10-year depletion rule, the Eligible Designated Beneficiary (EDB) categories, and the stretch IRA grandfathering for pre-2020 accounts all remain from SECURE 1.0. SECURE 2.0 modified specific provisions around RMD ages, penalties, and plan design rules.

Because inherited IRA planning depends heavily on whether the original owner died before or after their Required Beginning Date (RBD), any change to the RMD age automatically changes how you categorize beneficiaries — and whether annual distributions are required during the 10-year window under the 2024 IRS final regulations.²

Change 1: RMD age moved to 73 (and eventually 75)

Section 107 of SECURE 2.0 raised the age at which IRA owners must begin required minimum distributions.¹

The Required Beginning Date (RBD) is always April 1 of the calendar year following the year the owner reaches their applicable RMD age. So for someone born in 1951 who turns 73 in 2024, the RBD is April 1, 2025 — not the moment they turn 73.

Why this matters for inherited IRA beneficiaries

The IRS final regulations (T.D. 10001, July 2024) require beneficiaries to take annual RMDs in years 1–9 of the 10-year window only if the original owner died after their Required Beginning Date.² If the owner died before their RBD, no annual RMDs are required — just full depletion by December 31 of year 10.

SECURE 2.0's RMD age increase shifted the RBD forward in time for owners born 1951–1959 and 1960+. Some owners who appear to have been "required to take RMDs" based on their age are actually pre-RBD when the law is correctly applied. This is one of the most common misapplications of the inherited IRA rules.

This is distinct from someone born in 1951 who dies in 2025 at age 74. By April 1, 2025, their RBD had passed — so they are post-RBD, and their beneficiary must take annual RMDs in years 1–9.

The pre-RBD/post-RBD determination table

For owners subject to SECURE 2.0 RMD ages, here is the earliest date at which the owner has passed their RBD:

If the original IRA owner died before the date in the right column, they were pre-RBD. If they died on or after that date, they were post-RBD. This single determination controls whether you as the beneficiary owe annual RMDs during years 1–9 of your 10-year window.

To calculate your annual RMD if you are in the post-RBD bucket, see the Inherited IRA Annual RMD Calculator.

Change 2: Missed RMD penalty cut from 50% to 25% (and 10%)

Section 302 of SECURE 2.0 reduced the excise tax on missed required minimum distributions.¹

The "correction window" is generally the earlier of: (a) the date the IRS sends a notice of deficiency or assessment, or (b) two years from the taxable year when the shortage occurred. In practice, self-correcting within roughly two years by taking the missed distribution and filing Form 5329 Part IX with a reasonable-cause explanation is the most reliable path to the 10% rate.

Why this matters for inherited IRA beneficiaries specifically

The IRS waived annual inherited IRA RMD penalties for tax years 2021 through 2024 (IRS Notices 2022-53, 2023-54, and 2024-35) while the T.D. 10001 regulations were being finalized.³ Those waivers ended. Starting with distributions required in 2025, beneficiaries who owe annual RMDs (because the original owner died post-RBD) must take them or face the 25% excise tax.

Importantly, because the waivers ended after SECURE 2.0 was already in effect, the first generation of beneficiaries facing this penalty will face 25% — not the old 50%. That is a meaningful improvement, but a missed $50,000 annual RMD still generates a $12,500 excise tax bill (or $5,000 at the 10% correction rate). The stakes are high enough to require careful tracking.

See the full remediation walkthrough in Missed an Inherited IRA RMD? — including the Form 5329 Part IX process and a reasonable-cause waiver letter template.

Change 3: Roth 401(k) lifetime RMD elimination and its consequence for beneficiaries

Section 325 of SECURE 2.0 eliminated required minimum distributions during the account owner's lifetime for designated Roth accounts in 401(k), 403(b), and governmental 457(b) plans, effective for years beginning January 1, 2024.¹ Before 2024, Roth 401(k) participants were required to take lifetime RMDs — unlike Roth IRA owners, who have never had lifetime RMDs.

After 2024, designated Roth accounts in workplace plans are treated the same as Roth IRAs: no lifetime RMD requirement, meaning the account owner has no Required Beginning Date.

Why this matters for beneficiaries of inherited Roth workplace plans

The T.D. 10001 annual-RMD rule for years 1–9 of the 10-year window is triggered only when the original owner died after their RBD. For Roth IRA owners, there is never an RBD (no lifetime RMDs), so inherited Roth IRAs have never required annual distributions — just full depletion by year 10.

Before SECURE 2.0, a Roth 401(k) owner who was past 72 had a Required Beginning Date for their designated Roth account. A beneficiary inheriting that account after the owner's RBD theoretically owed annual RMDs.

After SECURE 2.0 Section 325, Roth 401(k)/403(b)/457(b) participants have no lifetime RMD requirement and no RBD. For beneficiaries inheriting these accounts from owners who died after 2023: there is no RBD, so annual RMDs are never required during the 10-year window. Only full depletion by year 10 applies.

For inherited Roth 401(k) accounts where the owner died before 2024 (before Section 325 took effect): the pre-2024 rules may still be relevant. If the owner had a Required Beginning Date under the old pre-2024 rules and died after that date, consult a specialist — the rules during this transition window are nuanced. See Inherited 403(b) Rules and Inherited 457(b) Rules for plan-specific guidance.

Change 4: QLAC limit doubled (less commonly relevant)

Section 202 of SECURE 2.0 increased the Qualified Longevity Annuity Contract (QLAC) limit from $145,000 to $200,000 and removed the prior 25%-of-account-balance cap.¹

For inherited IRA beneficiaries, this matters indirectly: if the original IRA owner had a QLAC inside their IRA, the annuity contract continues to named beneficiaries when the owner dies. The increased limit means more owners may have had larger QLACs inside their IRAs going forward. The annuity payments to the beneficiary are taxable ordinary income — and the QLAC balance is not part of the inherited IRA RMD calculation.

Most inherited IRA beneficiaries will not encounter a QLAC — but if the decedent's IRA custodian shows a balance that is partially an annuity contract, this is why.

What SECURE 2.0 did NOT change for inherited IRAs

Several aspects of inherited IRA rules are commonly misattributed to SECURE 2.0 but originate from other laws or regulations:

The single most important rule — that you must fully deplete an inherited IRA within 10 years — has not changed since SECURE 1.0 enacted it in 2019. SECURE 2.0 did not extend, shorten, or create any exception to the 10-year rule. It only changed factors that affect the planning within that window.

How SECURE 2.0 interacts with the T.D. 10001 final regulations

Much of the practical complexity in inherited IRA planning in 2025–2026 comes from the combination of two things: SECURE 2.0's RMD age changes (effective 2023) and the IRS final regulations in T.D. 10001 (effective January 1, 2025), which established when annual RMDs are required during the 10-year window.

These two instruments work together:

1. SECURE 2.0 Section 107 determines the owner's RBD (by setting the applicable age at 73 or 75).
2. T.D. 10001 then uses that RBD to determine whether the owner's beneficiaries owe annual RMDs in years 1–9.

Neither can be read in isolation. A beneficiary who applies only the SECURE 1.0 RMD age of 72 to a 2024 decedent born in 1952 will misclassify that decedent as post-RBD when they are actually pre-RBD under SECURE 2.0 — and incorrectly impose an annual RMD obligation on themselves that does not exist.

For the full annual RMD calculation framework, see Inherited IRA RMD Rules. For the pre-RBD/post-RBD determination in plain language, see The SECURE Act 10-Year Rule Explained.

Practical checklist: applying SECURE 2.0 to your inherited IRA

1. Look up the original owner's birth year. Use the table above to identify their RMD age (73 or 75) and their earliest possible RBD date.
2. Compare the date of death to the RBD. If they died before the April 1 date in the table, they are pre-RBD. No annual RMDs required during your 10-year window.
3. If the account is a Roth 401(k)/403(b)/457(b) and the owner died after 2023: No annual RMDs under Section 325. Defer all distributions to year 10 for maximum tax-free compounding, or take tax-free distributions earlier if you have other reasons to do so.
4. If you are in the post-RBD bucket: Calculate your year-1 annual RMD using the Single Life Expectancy Table (IRS Publication 590-B) and set a calendar reminder for December 31 of each distribution year. Use the Annual RMD Calculator to project the full schedule.
5. If you missed 2025 annual RMDs: Self-correct using Form 5329 Part IX within the correction window to qualify for the 10% penalty rate (not 25%). See Missed an Inherited IRA RMD?
6. Plan the full 10-year window. Your annual RMD is the minimum. In most cases, bracket-optimized distributions exceeding the minimum are worth modeling — see 10-Year Distribution Strategy and the Roth Conversion Coordinator.

Sources

1. Consolidated Appropriations Act, 2023 (P.L. 117-328), Division T — SECURE 2.0 Act of 2022. Signed December 29, 2022. Section 107 (RMD age), Section 202 (QLAC), Section 302 (missed RMD penalty), Section 325 (Roth designated account lifetime RMD elimination).
2. T.D. 10001 — Final Regulations on Required Minimum Distributions (Federal Register, July 19, 2024). Effective January 1, 2025. Established that non-EDB beneficiaries of post-RBD decedents must take annual RMDs in years 1–9 of the 10-year window. Also addressed Roth designated account inherited accounts (treated as pre-RBD since the employee has no RBD under Section 325).
3. IRS Notice 2024-35 — Relief from Required Minimum Distribution Penalties for 2024. Final year of waived penalties for inherited IRA annual distributions (beneficiaries of post-RBD decedents); extends prior Notices 2022-53 and 2023-54. Relief does not apply to 2025 or later years.
4. IRS Publication 590-B, Distributions from Individual Retirement Arrangements (IRAs). Contains the 2022 Single Life Expectancy Table (updated per T.D. 9930) used for annual RMD calculations by inherited IRA beneficiaries, and the Uniform Lifetime Table used by IRA owners. Values verified per 2025 edition.
5. IRS — Retirement Plan and IRA Required Minimum Distributions FAQs. Confirms SECURE 2.0 RMD ages: 73 for those born 1951–1959, 75 for those born 1960 and later. RBD is April 1 of the year following the year the applicable age is reached.

SECURE 2.0 rules verified as of June 2026. IRS regulations and transition guidance continue to evolve — consult a qualified tax or financial advisor for your specific situation before taking or deferring any distribution.