ERISA Strategist
Key takeaways
- Since Trump Accounts are intended to begin accepting contributions as of July 5, 2026, this “first installment” of guidance is focused on requirements for getting accounts opened for as many eligible individuals (children) as possible.
- To enable eligible children to receive the $1,000 federal government pilot program as soon as possible, this guidance also focuses on the procedures for a parent or other authorized individual making the required affirmative election.
- Further, more comprehensive guidance on other issues is expected later this year.
The proposals
The first proposal provides guidance on making an election to open a Trump Account and impacts children eligible to have a Trump Account, individuals who would make elections for those eligible children, and the institutions that will serve as trustees of Trump Accounts. The public comment period for this proposal is 60 days and ends May 8, 2026.
The second proposal relates to the Trump Accounts contribution pilot program that will provide a one-time $1,000 contribution from the federal government to the account of each eligible child for whom an election has been made to receive it. The public comment period for this proposal is 30 days and ends April 8, 2026.
The proposals generally provide limited guidance, which follows previous Treasury guidance provided in Notice 2025-68. Many sections in the proposals are currently “reserved” and will cover contributions (including employer-provided options), investments, distributions, reporting and other special rules. Further, more comprehensive guidance is expected in the second half of this year once the accounts become operational as of July 4, 2026. Key details of the proposals follow.
Here's what we do know
Account establishment
- A Trump Account is a form of traditional IRA (non-Roth, non-annuity) subject to special rules (among them, no distributions permitted) during the account’s “growth period” which begins on the date of establishment through December 31 of the year the child (“account beneficiary”) turns age 17.
- “Initial Trump Accounts” must be opened by Treasury at the election of an “authorized individual” which is a legal guardian, parent, adult sibling or grandparent (in that order). Treasury requested comments as to whether those terms should be specifically defined, whether additional relationships should be considered and how the regulations should address foster children, wards of the state and emancipated minors.
- Accounts may be established by filing IRS Form 4547 with the authorized individual’s tax return or electronically through the trumpaccounts.gov website. There is no automatic enrollment.
- Following the establishment of the initial Trump Account, the authorized individual may establish a rollover Trump Account with a provider of their choice. The entire amount of the initial Trump Account must be transferred to the rollover Trump Account to ensure the account beneficiary has only one Trump Account. Guidance on the rollover process will be forthcoming.
- After initial account establishment, the authorized individual is the responsible party with authority to make decisions for the account including investment selection (where available), directing a rollover to a new provider or to an ABLE account, and selecting a successor responsible party, if needed.
- Trump Accounts must be maintained under a written document specifying all applicable rules including restrictions on contributions, investments, distributions and reporting during the growth period. The document must designate the account as a Trump Account.
- The initial trustee has not yet been announced by Treasury.
- Banks and IRS-approved non-bank custodians may hold rollover Trump Accounts following initial establishment. Non-bank custodians approved by the IRS prior to December 31, 2025, may serve as Trump Account custodians. Additional Treasury rules for applications in 2026 and later are under consideration.
- After the end of the growth period, traditional IRA rules apply with the exception of the ability to receive contributions from a SEP or SIMPLE IRA.
Pilot program contributions
- Trump Accounts may be established for “eligible individuals” defined as children under age 18 who are U.S. citizens and who have been issued a social security number as of the date the account is established.
- Each eligible individual born between January 1, 2025, and December 31, 2028 is an “eligible child” for purposes of the one-time $1,000 pilot program contribution.
- A pilot-program contribution election may be made by an authorized individual on behalf of an eligible child who is anticipated to be that individual’s qualifying child under Internal Revenue Code section 152(c) for the taxable year of the election. This individual is defined as the “pilot program-electing individual.”
- The election may be made at any time from the establishment of the Trump Account through December 31 of the year the eligible child turns 17 and must include the eligible child’s social security number. This timing can allow account establishment and pilot program elections within a few weeks of birth for maximum investment growth potential.
- Elections may be made by filing IRS Form 4547 in 2026. The Secretary of the Treasury may prescribe a different form and/or online instructions after 2026.
- Pilot program contributions are structured as a refund of a deemed overpayment of taxes by the eligible child.
Scale, urgency and what is next
The proposal on account establishment is expected to affect 73 million children under age 18, in 44 million families. While there is no deadline before December 31 of the year an eligible individual reaches age 17, Treasury Department and IRS demonstrate the economic benefits of Trump Account establishment and investment as early as possible. Furthermore, the temporary pilot contribution program is expected to affect 15 million children in 12 million families, and the timing under the proposal provides opportunity to maximize account growth potential over the growth period.
Additional comprehensive guidance (contributions, employer options, investments, distributions, reporting, special rules) is expected in the second half of 2026 as accounts become operational around July 4–5, 2026.
Now is an opportune time for families to consider jumpstarting childhood saving and investing for a bright future by establishing Trump Accounts for eligible children.
For additional information, see the below slide entitled “Trump accounts: An early start to saving for children” in the Guide to Retirement.