Inherited IRA Rules: The Annual RMD Most Beneficiaries Don't Know They Owe

At a glance: If you inherited an IRA from someone who died after 2019, the SECURE Act gives you a hard deadline: the account must be empty by December 31 of the tenth year after the year of death. What most heirs never hear is the second rule inside the first: if the owner died on or after their required beginning date — they had already started their own RMDs — you also owe an annual RMD in each of years 1 through 9, figured on your own life expectancy (final IRS regulations, T.D. 10001, from 2025). The IRS waived the penalty for those annual amounts in 2021–2024; the waivers are over. Miss a year-end RMD now and the excise tax is 25% of the shortfall — 10% if corrected in time. For a 2024 death, the 2026 annual RMD is due Thursday, December 31, 2026, and the account must be empty by December 31, 2034.

---

For forty years, inheriting an IRA came with a gift most heirs never fully appreciated: the stretch — small life-expectancy payments while the rest compounded for decades. The SECURE Act of 2019 ended that for most non-spouse beneficiaries of owners who died after 2019, replacing it with a ten-year window — but it left one question genuinely open: are amounts owed inside the window, or only at the end of it? The IRS's answer, finalized in July 2024, is the one now catching families: if the person you inherited from had already begun their own required distributions, yours continue too, every year, on a December 31 deadline carrying a 25% penalty.

Two rules, not one: the 10-year deadline and the annual RMD inside it

The outer rule is the one in every headline. Publication 590-B states it flatly: "The 10-year rule requires the IRA beneficiaries who are not taking life expectancy payments to withdraw the entire balance of the IRA by December 31 of the year containing the 10th anniversary of the owner's death." Die in 2024, and the account must be empty by December 31, 2034. It applies to any designated beneficiary — an individual named on the account — who is not in the excepted group below, whether or not the owner had started RMDs.

The inner rule was argued about for four years. The tax code's "at least as rapidly" principle says distributions begun during the owner's life must continue at least as fast after death. The IRS read that into the 10-year rule in its 2022 proposed regulations; commenters pushed back, arguing for the old 5-year rule's shape — nothing owed until the final year. The final regulations, issued July 18–19, 2024 (Treasury Decision 10001, 89 FR 58886), kept the IRS's reading: "Treasury and IRS determined that the final regulations should retain the provision in the proposed regulations requiring such a beneficiary to continue receiving annual payments," even when the balance will be fully distributed within ten years. The regulations apply for distribution years beginning on or after January 1, 2025 — why 2025 was the first year this annual RMD carried a real penalty, and 2026 is the second.

The fork that decides everything: when the owner died relative to their required beginning date

Everything here turns on one fact about the person you inherited from: had they reached their required beginning date — April 1 of the year after they reached RMD age — before they died?

The owner's situation at death	What you owe
Died before their required beginning date	No annual RMDs. Publication 590-B: if the 10-year rule applies and the owner died first, "no distribution is required for any year before the 10th year." Take what you want, when you want — but the account must still be empty by the year-10 deadline.
Died on or after their required beginning date (already taking RMDs)	Annual RMDs in years 1–9, figured on your life expectancy, plus the entire remainder out by the year-10 deadline. This is the trap this guide exists for.
The account is an inherited Roth IRA	A Roth owner has no required beginning date in life — there are no lifetime RMDs from a Roth IRA — so the annual-RMD trigger never fires. The IRS applies the same beneficiary framework to inherited Roth IRAs, so the 10-year deadline still applies; only the annual amounts drop out.

One more duty sits in front of all three rows: for the year of the owner's death, whatever RMD the owner was required to take that year and hadn't is yours to take by that December 31 (the IRS's Beneficiary page, in one line). If your parent died in March having taken none of that year's RMD, the full amount was due from you by the end of the death year — before your own year-1 schedule starts.

Get the free one-page Inherited IRA Deadline Tracker — your year of death, your category, and a check-off line for every December 31 from 2026 through the 2034 emptying deadline. Get the free tracker (PDF) → or have it sent to your inbox →.

The penalty waivers are over — and they never moved your deadline

If you half-remember that the IRS "wasn't enforcing" this rule, you remember correctly — for a while. While the regulations were unfinished, three IRS notices excused the missed annual amounts for beneficiaries under the 10-year rule: Notice 2022-53 covered 2021 and 2022, Notice 2023-54 covered 2023, and Notice 2024-35 covered 2024 (Publication 590-B's reminders carry the last one). No notice covered 2025, and none is coming; the final regulations are in force.

Two things the waivers did not do, both stated in the final regulations themselves: they did not require anyone to make up the skipped 2021–2024 distributions, and they did not extend the 10-year deadline by a day — an owner who died in 2020 leaves a beneficiary who must still distribute the remaining balance in 2030. The relief forgave four years of annual amounts while the clock underneath kept running. If you inherited from a post-RBD owner in 2020–2023, you are mid-window right now; your next annual deadline is December 31, 2026.

Who still gets the old stretch: eligible designated beneficiaries

Congress kept life-expectancy payments for a short list of heirs. An eligible designated beneficiary — measured as of the owner's death — is one of these five:

Category	What they may do
The owner's surviving spouse	The widest menu of any heir — see the spouse section below.
The owner's minor child	Life-expectancy payments until the age of majority — which the final regulations fix at 21 — then the 10-year rule takes over the remainder, ending December 31 of the year containing the 10th anniversary of the child's 21st birthday. The owner's child only; a grandchild does not qualify.
A disabled individual	Life-expectancy payments, under the tax code's disability definition.
A chronically ill individual	Life-expectancy payments, under the tax code's chronic-illness definition.
Anyone not more than 10 years younger than the owner	Life-expectancy payments — the sibling-or-partner case.

An eligible designated beneficiary takes payments over their own life expectancy — or, if the owner died on or after their required beginning date, over the longer of the two lives (mechanics in the next section). If the owner died before their required beginning date, an eligible designated beneficiary may instead elect the 10-year rule. Everyone else who is an individual is a plain designated beneficiary on the 10-year clock; a non-individual (an estate, a charity) is not a designated beneficiary at all, and the older rules apply. Note only that the beneficiary determination is made on September 30 of the year after the death — the first year after a death is paperwork season, not a waiting room.

How the annual amount is figured: one divisor, set once, minus one a year

Run your inherited-IRA schedule with our free RMD Calculator, which includes the inherited-IRA mode.

The annual RMD inside the 10-year window uses the beneficiary's life expectancy — but not the way an owner's RMD does:

• The formula. Prior December 31 balance ÷ your factor from Table I (Single Life Expectancy), Appendix B of Publication 590-B.
• The factor is set once. Find the Table I factor for your age in the year after the owner's death. Then reduce it by one for each year after that. It is never recalculated: a 55-year-old's 31.6 becomes 30.6, then 29.6, then 28.6.
• The longer-of test. If the owner died on or after their required beginning date, the law uses the longer of two factors: yours, or the owner's remaining factor — the owner's Table I factor at their age in the year of death, also reduced by one each year. A younger heir's factor is almost always longer — but with a beneficiary close to the owner's age, run both.
• No custodian safety net. An IRA owner gets an RMD statement every January; a beneficiary may not. Publication 590-B notes that no RMD report is required for IRAs of owners who have died — and the beneficiary is "ultimately responsible for taking the correct RMD amount."
• Aggregation is narrow. If you inherited several IRAs from the same person, figure each one's RMD separately, then take the total from any one of them. An inherited IRA never aggregates with your own IRA, or with an IRA inherited from someone else.

The example: a father, a daughter, and a $7,843.14 deadline

(The people below are hypothetical. The rules, table factors and penalty rates are the IRS's; the balance is a stated round figure.)

Karen's father died in March 2024, at 78 — long past his required beginning date, having taken his own RMDs for years. Karen, his sole designated beneficiary, is not an eligible designated beneficiary: she is 23 years younger. She is on the 10-year clock — empty by December 31, 2034 — and she owes annual RMDs in years 1–9 (2025–2033).

The step	The math	The result
Her factor is set (2025, year 1)	She turned 55 in 2025 — Table I factor for 55	31.6
The longer-of test (2025)	Father's factor: Table I at 78 = 12.6, minus 1 = 11.6. Hers (31.6) is longer	Hers governs
Her 2026 factor (year 2)	31.6 − 1	30.6
Her 2026 RMD	Inherited IRA balance $240,000 on December 31, 2025 ÷ 30.6	$7,843.14, due Thursday, December 31, 2026

Now price the miss, because the miss is the story of this rule. If Karen takes nothing in 2026, the excise tax is 25% of $7,843.14 = $1,960.78. Correct the shortfall inside the correction window and the rate falls to 10%: $784.31. A partial miss prices the same way: take only $3,000 of it, and the $4,843.14 shortfall draws $1,210.78 at 25%. Scale it up — a missed $15,000 annual RMD is a $3,750 penalty. The owner-side version of this same penalty is worked in our RMD deadline guide.

Already missed one? The fix-it sequence

• Missed a 2021–2024 annual RMD? Nothing to fix. The three notices waived those years for 10-year-rule beneficiaries, and the final regulations confirm no make-up distribution is required.
• Missed the 2025 RMD? That one was not waived — 2025 was the first enforced year. Take the full missed amount now (taxable income in the year you receive it), then file Form 5329 with your 2025 return reporting the shortfall. Taking it promptly puts you inside the correction window for the reduced 10% rate instead of 25%.
• Ask for the waiver too. The penalty "may be waived if the account owner establishes that the shortfall in distributions was due to reasonable error and that reasonable steps are being taken to remedy the shortfall" — claimed by filing Form 5329 with a letter of explanation. Four years of contested guidance is the strongest reasonable-error story this corner of the tax code has ever produced.
• Then fix the system, not just the year. Set the distribution for early December, every year, from the inherited account itself — the deadline attaches to the money leaving, not to your intention.

What does not work: four shortcuts that aren't

• "I'll give it to charity from the inherited IRA." A qualified charitable distribution requires the giver to be at least 70½ on the day of the distribution — and for an inherited IRA, that age test runs on you, the beneficiary, not on the person who died (Publication 590-B's QCD definition; IRS Notice 2007-7, A-37). A 55-year-old heir cannot make a QCD at all. A beneficiary who is over 70½ can — the mechanics and the $111,000 cap are in our QCD playbook.
• "I'll convert it to a Roth." Not permitted. Publication 590-B, to non-spouse beneficiaries: "you can't make any contributions to the IRA. It also means you can't roll over any amounts into or out of the inherited IRA" — and a conversion is a rollover. The only move allowed is a trustee-to-trustee transfer into another IRA still titled in the deceased owner's name for your benefit.
• "I'll take double next year." Excess distributions never carry forward: take more than the minimum in one year and you get no credit against the next year's requirement — the IRS's FAQ answers this in a single word: "No."
• "I'll just disclaim it." A qualified disclaimer is a real tool with a short fuse: an irrevocable refusal in writing, received within 9 months of the death that created the interest (Internal Revenue Code §2518), and it fails if you have already accepted any benefit from the account. For a 2024 inheritance, that window closed in 2024. For a recent death, it is the one decision here worth a lawyer's hour before you touch the money.

If you're the spouse, your rulebook is different — briefly

A surviving spouse who is the sole beneficiary has options no one else gets. You may treat the inherited IRA as your own — or roll it into your own IRA — after which it follows your RMD schedule. Or you may remain a beneficiary, taking life-expectancy payments; a sole-spouse beneficiary even gets the system's one recalculation privilege, the factor re-determined from Table I each year instead of ticking down. The 10-year rule is also available to a spouse in the cases the IRS lists. Which door is right depends on your ages and income — genuinely a planning decision, and not the 25%-penalty clock written for designated beneficiaries above.

---

Keep every December 31 on one page: the free Inherited IRA Deadline Tracker takes your year of death, the owner's RMD status and your category, then gives you a check-off line for each year — annual RMD years 2026–2033 and the 2034 emptying deadline — with the divisor rule on the same page. Get the free tracker (PDF) → or have it emailed to you →. It also lives on our Worksheets page with the rest of the Desk's free printables.

Frequently asked questions

I inherited in 2024 and took nothing in 2025. Am I in trouble?

You missed the first enforced year; the 2021–2024 waivers do not cover 2025. The fix: take the full missed amount now, file Form 5329 for 2025, and you are inside the correction window for the 10% rate instead of 25% — with a reasonable-error waiver request on top.

The owner died before starting RMDs. Do I owe annual amounts?

No. Publication 590-B is explicit: under the 10-year rule, when the owner died before their required beginning date, "no distribution is required for any year before the 10th year." You choose the timing — the only hard date is the year-10 emptying deadline.

It's an inherited Roth IRA. Do the annual RMDs apply?

No annual amounts — a Roth owner never reaches a required beginning date, because Roth IRAs have no lifetime RMDs, so the trigger never fires. But the IRS applies the same beneficiary framework to inherited Roth IRAs, so the 10-year deadline applies in full: empty by December 31 of the tenth year after the year of death.

Can I satisfy this RMD from my own IRA, or from an IRA I inherited from someone else?

No to both. Inherited IRAs aggregate only with other IRAs inherited from the same decedent: figure each separately, then withdraw the combined total from any one of them.

Sources & official figures

• Internal Revenue Service — News Release IR-2024-190 (July 18, 2024) (checked October 25, 2026): the final RMD regulations retain "the provision in the proposed regulations requiring such a beneficiary to continue receiving annual payments": https://www.irs.gov/newsroom/treasury-irs-issue-updated-guidance-on-required-minimum-distributions-from-iras-other-retirement-plans-generally-retains-proposed-rules
• Treasury / IRS — Final regulations: Required Minimum Distributions, Treasury Decision 10001, 89 FR 58886 (July 19, 2024) (checked October 25, 2026): effective September 17, 2024; applies "for calendar years beginning on or after January 1, 2025"; missed 2021–2024 amounts need not be made up; the 10-year deadline is not extended: https://www.federalregister.gov/documents/2024/07/19/2024-14542/required-minimum-distributions
• Internal Revenue Service — Publication 590-B (2025), ch. 1 and Appendix B (checked October 25, 2026): the 10-year rule and its 10th-anniversary deadline; "no distribution is required for any year before the 10th year" (owner died before RBD); EDB categories; the Table I method and Table I itself (55 → 31.6; 78 → 12.6); no RMD statement for a deceased owner's IRA; the nonspouse no-rollover rule; excess accumulations — 25% excise tax, 10% correction-window rate, Form 5329, reasonable-error waiver; the Reminder carrying Notice 2024-35: https://www.irs.gov/publications/p590b
• Internal Revenue Service — Retirement topics – Beneficiary (checked October 25, 2026): beneficiary RMD determination; the year-of-death RMD owed by beneficiaries; the beneficiary categories for deaths in 2020 or later; Notice 2022-53 relief for 2021–2022; inherited Roth IRAs "subject to the same RMD requirements as inherited traditional IRA accounts": https://www.irs.gov/retirement-plans/plan-participant-employee/retirement-topics-beneficiary
• Internal Revenue Service — Retirement plan and IRA required minimum distributions FAQs (checked October 25, 2026): the 10-year rule and exceptions; Table I; beneficiary responsibility; 25% / 10%-if-corrected excise tax, Form 5329; reasonable-error waiver; no carryforward of excess: https://www.irs.gov/retirement-plans/retirement-plans-faqs-regarding-required-minimum-distributions
• Internal Revenue Service — Retirement topics: Required minimum distributions (RMDs) (checked October 25, 2026): "you may have to pay a 25% excise tax on the amount not distributed as required (10% if withdrawn within 2 years)"; no lifetime RMDs from a Roth IRA: https://www.irs.gov/retirement-plans/retirement-plans-faqs-regarding-required-minimum-distributions
• Internal Revenue Service — Notice 2023-54, 2023-31 I.R.B. 383, as catalogued in the IRS's 2026 Cumulative List of Changes in Plan Qualification Requirements (IRB 2026-23): "provides relief with respect to certain required minimum distributions for 2023."
• Internal Revenue Code §2518(b)(2) (checked October 25, 2026): a qualified disclaimer must be in writing and received "not later than the date which is 9 months after" the transfer creating the interest: https://www.law.cornell.edu/uscode/text/26/2518
• Internal Revenue Service — Notice 2007-7, Q&A-37 (verified in the Article 11 build, October 25, 2026): a beneficiary who is at least 70½ may make a QCD from an inherited IRA — the age test runs on the beneficiary.

Last updated: October 25, 2026 — checked against IRS sources on October 25, 2026. If the IRS republishes its beneficiary guidance or issues new transition relief, the affected lines above are refreshed the same day.

Disclaimer: The Retirement Desk publishes education, not financial, tax, or legal advice. The worked example is a labelled hypothetical with a stated balance; your deadlines depend on the owner's death date and RMD status, your beneficiary category, and the account's documents — the IRS and the custodian's records are the authorities on them. Cases involving trusts, multiple beneficiaries, or a missed year already behind you are worth a tax professional's review.

Filed under: Inherited IRA — The Retirement Desk, the situation-first retirement money desk for Americans 60–75.