A late required minimum distribution can catch you by surprise, especially when you know you withdrew money from your retirement account.
You checked the account. The payment went through. You may even have a Form 1099-R showing the distribution. Then an IRS notice arrives saying the RMD was late or too small.
How can both things be true?
The answer may come down to a detail that was easy to miss. The withdrawal may have been completed after the deadline, calculated incorrectly, or taken from an account that could not satisfy the RMD for another plan.
The goal is not to panic. Start by checking the required amount, the deadline, the account involved, and the date the money was actually distributed.
What a Late Required Minimum Distribution Actually Means
An RMD is the minimum amount that generally must leave a covered retirement account for the year. It is not enough to show that you took some money out.
The IRS looks at whether the full required amount was distributed by the applicable deadline. If the required amount was $8,400 and you withdrew $8,000, the potential shortfall is $400. If the full amount left the account after the deadline, it may still be treated as late.
That distinction matters. A Form 1099-R proves that a distribution was reported. It does not, by itself, prove that the correct RMD was completed on time.
Which RMD Deadline Applied to You?
Most annual RMDs are due by December 31. Your first RMD can work differently.
Under current IRS guidance, many retirement-account owners generally begin RMDs for the year they reach age 73. The first RMD may be delayed until April 1 of the following year. If you use that delay, the next RMD is still due by December 31 of that same year.
That can create two taxable distributions in one year. Learn more in IRSProb’s guide to retirement tax planning.
Workplace plans can have another rule. A participant may be able to delay RMDs from the plan maintained by an employer for whom the participant continues working, if the plan permits it. The exception generally does not postpone RMDs from former employers’ plans, and it does not apply to someone who owns more than 5% of the business sponsoring the current plan. It also does not delay traditional IRA RMDs.
Review the IRS required minimum distribution FAQs before assuming that age or employment gives you more time.
Why the IRS May Say Your RMD Was Late
The Distribution Was Completed After the Applicable Deadline
You may have submitted the request in December, but the custodian did not complete the distribution until January. A request date and a completed distribution date are not always the same.
Do not rely only on the date you called or clicked a button. Review the transaction confirmation, account statement, deposit record, and Form 1099-R.
The Amount Was Too Small
An RMD is generally calculated using the prior December 31 account balance and an IRS life-expectancy factor. Using the wrong balance or table can create a shortfall.
Custodians often provide estimates, but the account owner is ultimately responsible for taking the correct amount.
The Money Came From the Wrong Account
Some retirement accounts can be combined for RMD withdrawal purposes. Others cannot.
Taking a large amount from an IRA does not automatically satisfy an RMD owed by a 401(k). The same problem can arise when someone combines unrelated inherited accounts.
The First RMD Was Delayed
Some people delay their first RMD until April 1 and then forget that another RMD is due by December 31. The April payment satisfies the prior year’s requirement. It does not replace the RMD for the current year.
An Inherited Account Followed Different Rules
Inherited IRA rules depend on the original owner’s date of death, whether the owner had reached the required beginning date, and the beneficiary’s status. The 10-year rule does not always mean that no annual distribution is required.
For example, an individual beneficiary who is not an eligible designated beneficiary and who inherited from an owner who died on or after the required beginning date generally may need annual distributions while also emptying the account by the end of year 10. Different rules can apply when the owner died before that date.
The IRA Beneficiaries section of IRS Publication 590-B explains the current framework. Do not apply the owner’s lifetime rules without checking the facts.
A Simple Late RMD Example
Consider this hypothetical situation.
Your RMD for the year is $9,200. Assume December 31 is the applicable deadline. You submit an online request for $9,200 on December 29, but the custodian confirms that no distribution occurred before January 3.
You requested the correct amount, but no distribution was completed by December 31.
If only $9,000 was distributed before year-end, the possible shortfall would be $200, not the full $9,200.
Can One Withdrawal Cover RMDs From Several Accounts?
Sometimes, but not always.
For traditional IRAs, including many SEP and SIMPLE IRAs, you generally calculate each RMD separately. You may then take the combined amount from one or more eligible IRAs.
A similar aggregation rule generally applies to multiple 403(b) contracts. You calculate each RMD, then may take the combined total from one or more of those 403(b) accounts.
Most other workplace plans are different. A 401(k), 457(b), or other qualified plan generally must satisfy its own RMD. You usually cannot take extra money from an IRA to cover a separate 401(k) requirement.
Inherited IRA distributions generally can be combined only when the accounts came from the same person and the applicable requirements are met.
Do not move an RMD into another retirement account as a rollover. An RMD is generally not eligible for rollover. IRSProb’s article about pension lump-sum withholding explains why confirming rollover eligibility matters.
What Is the Tax on a Missed or Short RMD?
The additional tax generally applies to the amount that should have been distributed but was not. The current general rate is 25% of that shortfall.
The rate may be reduced to 10% if, during the correction window, you receive the corrective distribution and submit a return reflecting the additional tax. The window ends at the earliest of a deficiency notice, an assessment, or the last day of the second taxable year beginning after the year in which the tax was imposed. Do not assume you always have two full years after receiving a notice.
Correcting the withdrawal is important, but it does not automatically finish the tax reporting.
How Form 5329 Is Used for a Late RMD
Form 5329 is generally used to report the additional tax on a missed or insufficient RMD. It is also used when asking the IRS to waive that tax because the shortfall resulted from reasonable error.
The form asks for the required amount, the amount distributed by the deadline, and the resulting shortfall. If you are requesting a waiver, the instructions explain how to mark the reasonable-cause amount and attach a statement.
Use Form 5329 for the tax year containing the missed deadline. For example, if a first 2026 RMD was delayed until April 1, 2027, missing that deadline generally creates a 2027 Form 5329 reporting issue. If you were not otherwise required to file a return, you may still need to file Form 5329 by itself.
Do not guess your way through it.
Can the IRS Waive the Late RMD Tax?
The IRS may waive part or all of the additional tax when the shortfall was caused by reasonable error and reasonable steps are being taken to fix it.
Relevant facts may include a serious illness, a death, a documented custodian mistake, or reasonable confusion involving an inherited account. Relief is not automatic.
A waiver request should explain what happened, when you discovered it, when the missing amount was distributed, and what you changed to prevent the problem from happening again. Attach supporting records when appropriate.
The IRS reviews the request and decides whether to grant it. Filing Form 5329 with an explanation is not the same as receiving approval.
What Records Should You Review?
Gather these records before responding:
- Prior December 31 account statements
- RMD calculation notices
- Distribution requests and confirmations
- Bank records showing receipt
- Forms 1099-R
- Beneficiary documents
- Plan or custodian correspondence
- Your tax return and any Form 5329 already filed
- The complete IRS notice
If you received a CP14I or another letter, read the tax year, amount, response instructions, and deadline. The IRS explains the current CP14I notice. IRSProb also has a practical guide on reviewing IRS mail before responding.
What to Do Next After Discovering a Late RMD
First, calculate the RMD again using the correct balance, age, table, account type, and beneficiary status.
Second, compare it with distributions completed by the deadline. Do not count a later payment as though it happened earlier.
Third, correct any remaining shortfall promptly. A later distribution does not rewrite the original deadline, but correcting the shortage can support a reduced rate or waiver request.
Fourth, determine whether Form 5329 is required and whether you are paying the additional tax or asking for reasonable-cause relief.
Fifth, answer any IRS notice by its deadline. If you disagree, explain why and show the calculation.
Finally, look at the wider tax effect. A catch-up distribution can increase taxable income and may affect Medicare costs later. IRSProb’s discussion of Medicare IRMAA mistakes explains that connection.
How to Prevent Another Late Required Minimum Distribution
Start before December. Confirm every covered account, calculate each RMD, and determine which amounts may be combined.
Leave time for processing. A year-end request can run into weekends, holidays, missing forms, or verification delays.
Save the payment confirmation and compare it with your calculation. Review automatic withdrawals every year because balances and life-expectancy factors change.
Review your retirement tax planning.
Read IRSProb’s related guide to retirement tax planning.
Review Retirement Tax PlanningFrequently Asked Questions About Late RMDs
Does Form 1099-R Prove My RMD Was on Time?
Not by itself. It reports a distribution, but you still need to confirm the applicable deadline, required amount, account, and transaction date.
Can I Take Extra Money Next Year to Fix a Missed RMD?
You should generally correct the prior shortfall promptly, but an extra payment does not reduce the RMD separately required for the new year. Form 5329 reporting may still be needed.
Can One IRA Withdrawal Cover All My IRA RMDs?
Often, yes, for eligible IRAs you own. You must calculate each IRA’s RMD first. Different rules apply to workplace plans and inherited accounts.
Do Roth IRAs Have RMDs During the Owner’s Lifetime?
Roth IRA owners generally do not have lifetime RMDs. Beneficiaries can have distribution requirements. Current rules also generally remove lifetime RMDs from designated Roth accounts in 401(k) and 403(b) plans.
Does a Qualified Charitable Distribution Count Toward an RMD?
A properly completed qualified charitable distribution can count toward an IRA RMD. It must meet the applicable QCD requirements. A normal donation made after receiving the money is not automatically treated as a QCD.
Can a Custodian Error Support a Waiver?
It may help establish reasonable error, but relief is not automatic. Correct the shortfall, preserve the records, and explain the steps taken.
Final Review
Taking a retirement withdrawal does not always mean the RMD rules were satisfied.
Check the amount, deadline, account, and completed payment date. If there was a shortfall, correct it promptly and review Form 5329 before responding to the IRS.
What matters most is what you do next.
