401(k) plan
Each 401(k) plan stands alone for RMD purposes. Three old 401(k)s from prior employers means three separate RMD calculations and three separate withdrawals. Aggregating across them is the most common single mistake we see.
Account type
401(k) plan
None — each 401(k) requires its own withdrawal
Uniform LifetimePub 590-B App. BTreas. Reg. §1.401(a)(9)-8 A-1
Key points
| Aggregation | Never aggregable. Each plan's RMD must be withdrawn from that specific plan. |
| Roth 401(k) post-2024 | SECURE 2.0 §325 — Roth 401(k) accounts are exempt from owner RMDs starting tax year 2024. |
| Still-working exception | If you are still working at age 73/75 for the employer that sponsors the 401(k) — and you do not own >5% of the company — you may delay your first RMD from THAT plan until April 1 after you separate from service. Other 401(k)s from former employers don't qualify. |
| Rollover strategy | Many users roll old 401(k)s to a Trad IRA before RBD age — this consolidates them into the IRA aggregation pool. Once you reach RBD, the rollover doesn't help with that year's RMDs. |
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Last verified: May 6, 2026 · Pub 590-B post-2022 (TD 9930) divisors.