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Guide

What Happens If You Miss an RMD—and How to Correct It

By TheFinanceBase Team 10 min read

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If you miss all or part of a required minimum distribution (RMD), the undistributed amount can be subject to an IRS excise tax. The general tax is 25% of the shortfall—not 25% of your entire retirement account. If you take the corrective distribution during the applicable correction window and meet the reporting requirements, the rate may be reduced to 10%. You can also ask the IRS to waive some or all of the tax when the failure resulted from reasonable error and you are taking reasonable steps to fix it, but approval is discretionary.

Take the missed amount as soon as practicable, keep proof of the payment, and report the shortfall for the tax year in which the RMD was due on that year’s Form 5329. Attach a clear waiver explanation if you are requesting relief. The deadline and calculation depend on the account, plan, owner or beneficiary status, and tax year, so do not assume that another account’s rules apply.

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What a missed RMD means

An RMD is the minimum amount that must be distributed from certain tax-deferred retirement accounts for a particular year. If the required amount is not distributed by the applicable deadline, the difference between what should have been distributed and what was actually distributed is an excess-accumulation shortfall. That shortfall, rather than the whole account balance, is the amount used to determine the potential excise tax.

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The missed amount generally remains taxable income when it is distributed. The excise-tax issue is separate: it addresses the failure to take the required amount on time. A later withdrawal does not automatically erase the earlier failure, so correcting the account and reporting the tax issue are two related but distinct tasks.

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The possible excise-tax rates

Situation Potential excise tax What controls the result
RMD shortfall not corrected under the reduced-rate rules 25% of the undistributed amount The applicable year’s Form 5329 instructions and the facts of the failure
Shortfall corrected within the correction window and reported as required 10% of the undistributed amount may apply Timely correction, reporting, and the year’s statutory requirements
Waiver requested for reasonable error Some or all of the tax may be waived The IRS decides whether the error was reasonable and whether reasonable remedial steps are being taken

These are statutory rates described in the IRS instructions, not estimates of how often people miss RMDs. A 10% result is not automatic merely because you withdraw the money later, and a waiver request is not an approval.

Why your exact RMD deadline matters

There is no single deadline that applies to every taxpayer. The date can depend on whether the distribution is for the account owner’s first RMD year, the type of account or employer plan, and whether the account belongs to a beneficiary. The applicable tax-year instructions and the plan or custodian’s records control.

First distribution year versus later years

For some owners, the first RMD year has a special deadline that can differ from the deadline for later years. Deferring that first distribution can result in two distributions being due in one calendar year. That timing affects which tax year each distribution satisfies and can change the amount you believe is missing.

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Account and beneficiary rules

Traditional individual retirement arrangements, workplace plans, inherited accounts, and other arrangements can use different calculation and deadline rules. Beneficiary status, the date of the owner’s death, and the applicable distribution regime can be decisive. Do not aggregate withdrawals across accounts unless the governing rules permit aggregation for those specific accounts. A custodian’s generic reminder is useful, but it is not a substitute for checking the rule that applies to your account and tax year.

What to do immediately after discovering the shortfall

  1. Confirm the required amount. Recalculate the RMD for the year it was due using the account balance and life-expectancy or beneficiary rules that applied for that year. Compare the required amount with every distribution that actually left the account by the deadline.
  2. Ask the custodian or plan administrator for the corrective distribution. Request the remaining amount as soon as practicable. Specify that it is a correction of the prior-year RMD shortfall, while recognizing that the account provider’s coding cannot replace your tax reporting.
  3. Record the payment. Save the request, confirmation, check or electronic-transfer record, gross amount, payment date, and account statement showing the distribution.
  4. Identify the correct tax year. The missed RMD is reported for the year in which it was due. If that year has already been filed, use that year’s Form 5329 and follow the instructions for a prior-year filing.
  5. Prepare the tax filing and any waiver request. Complete Form 5329 for the relevant year, attach an explanation if seeking a waiver, and pay any amount not covered by the requested waiver according to the instructions.
  6. Keep a complete file. Retain the calculation, statements, correspondence, proof of correction, filed form, explanation, and delivery confirmation.

Correcting quickly helps preserve access to the reduced-rate rules and gives you stronger evidence that you took reasonable remedial steps. Do not wait for an IRS notice before acting.

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How the correction window works

The IRS instructions describe a correction window that can allow the excise-tax rate to fall from 25% to 10% when the shortfall is corrected and reported in accordance with the rules. For the 2025 tax-year instructions, the window ends at the earliest of three events:

  • the IRS mails a notice of deficiency;
  • the IRS assesses the additional tax; or
  • the last day of the second taxable year beginning after the year in which the additional tax is imposed.

Because the endpoint is the earliest of these events, a notice or assessment can cut off the window before the two-year point. The exact form, deadline, and calculation are tax-year specific. Use the Form 5329 instructions for the year of the missed RMD, not simply the newest form available.

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How to report a missed RMD on Form 5329

Use the form for the year of the failure

Form 5329 is the IRS form used to report additional taxes on retirement arrangements, including an RMD shortfall. The return year matters. A missed RMD from an earlier year is not converted into a current-year failure just because you make the corrective distribution today.

Complete the applicable additional-tax section

Follow that year’s instructions to calculate the shortfall and the applicable additional tax. The instructions explain how to show the amount not distributed and how to handle a request for a reduced tax or waiver. Do not copy line references from a different year’s form; layout and line numbering can change.

Attach a concise waiver statement when appropriate

If you believe the failure resulted from reasonable error, attach a statement explaining:

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  • the amount of the RMD that was required;
  • the amount, if any, that was distributed on time;
  • the resulting shortfall;
  • why the failure occurred and why the error was reasonable;
  • the corrective distribution’s amount and date, or the steps already taken to obtain it; and
  • the amount of excise tax you are asking the IRS to waive.

The instructions describe using “RC” notation and identifying the amount requested for waiver. Include the evidence that supports the explanation, but keep the narrative factual and focused. The IRS says, “The IRS will review the information you provide and decide whether to grant your request for a waiver.” That means the request is reviewed case by case, not automatically accepted.

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File with a return or separately when allowed

If you are filing an income-tax return for the relevant year, the instructions generally explain how to attach Form 5329. If you are not required to file an income-tax return, the instructions provide a standalone filing method. Follow the delivery and payment directions for that specific year. Keep a copy of everything sent and proof of mailing or electronic submission.

How to make a persuasive reasonable-error request

Reasonable error is not a defined promise that covers every oversight. Your explanation should connect the facts to the missed distribution and show that you acted once you discovered the problem.

Facts that can help explain the error

  • an incorrect balance or beneficiary record supplied during the calculation;
  • a change of custodian, address, adviser, or account registration that interrupted a distribution instruction;
  • a documented processing or communication problem;
  • a death, incapacity, or other event that made timely administration difficult; or
  • a good-faith calculation mistake that was corrected promptly after discovery.

These examples do not guarantee relief. The quality of the records, the size and duration of the shortfall, and how quickly you corrected it can affect the IRS’s decision.

Show remedial action, not just an apology

State the date you discovered the shortfall, the date you contacted the custodian, the date the corrective payment was made or requested, and the steps you are taking to prevent a recurrence. Attach account statements or confirmations that make those dates verifiable. A bare statement that you forgot is less useful than a dated explanation supported by records.

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Pay tax that is not covered by the request

Report the tax and waiver amount as the instructions direct. If the IRS does not grant the requested relief, it may notify you that additional tax is due. A waiver request should not be treated as permission to ignore the amount shown by the form.

Employer-plan corrections are a separate process

If the missed RMD occurred in an employer-sponsored plan, the plan sponsor may also need to correct a plan-administration failure under the IRS Employee Plans Compliance Resolution System (EPCRS). That sponsor process does not replace the participant’s personal tax reporting.

Self-Correction Program (SCP)

EPCRS may allow a sponsor to self-correct certain failures under the Self-Correction Program. IRS guidance distinguishes SCP from a participant excise-tax waiver: SCP cannot waive the participant’s personal excise tax.

Voluntary Correction Program (VCP)

A sponsor may use the Voluntary Correction Program in circumstances where it seeks IRS approval of a correction and requests a waiver through the applicable procedure. The sponsor may use IRS model compliance-statement materials identified in the EPCRS guidance. Whether a VCP submission is appropriate is a plan-administration decision.

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If you are the participant, ask the plan administrator whether a plan correction is underway, but still address your own Form 5329 obligation. A sponsor’s EPCRS submission and your individual excise-tax filing are different matters.

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Common situations and the right response

Situation Immediate response Key caution
You missed the entire RMD and discovered it before filing Take the full corrective distribution, calculate the shortfall, and prepare the form and explanation. Use the deadline and form for the year in which the RMD was due.
You took part of the RMD Withdraw only the documented shortfall after reconciling all distributions. Do not pay a tax based on the full RMD if part was already distributed.
You discovered the issue after filing the original return Make the correction promptly and follow that year’s instructions for filing Form 5329 or an amended filing, as applicable. A current-year withdrawal does not change the year of the original failure.
You received an IRS notice Review the notice date, correct the account if possible, and respond using the notice and form instructions. The notice can be an endpoint of the reduced-rate correction window.
The account is in an employer plan Contact the plan administrator about EPCRS and separately evaluate your Form 5329 filing. SCP cannot waive your personal excise tax.

Errors to avoid while fixing an RMD

  • Waiting for the custodian to solve the tax filing. The custodian can process a payment, but the taxpayer remains responsible for reporting.
  • Using the current Form 5329 for an old failure without checking. Form details and instructions vary by tax year.
  • Assuming a later withdrawal erases the penalty. It corrects the account shortfall but does not automatically remove the excise tax.
  • Requesting a waiver without documenting correction. The IRS standard includes reasonable steps to remedy the failure.
  • Applying one account’s aggregation rules to another. Account and plan types can have different rules, especially for inherited accounts and employer plans.
  • Confusing the 25% or 10% rate with an income-tax rate. Those figures describe the potential excise tax on the shortfall.
  • Ignoring a notice while preparing a waiver. A deficiency notice or assessment can affect the correction window and response deadlines.

When professional help is worthwhile

Consider a qualified tax professional or retirement-plan adviser when the calculation involves an inherited account, multiple beneficiaries, a first-distribution-year deferral, several custodians, a prior-year return, an employer-plan correction, or an IRS notice. Bring year-end statements, distribution confirmations, beneficiary documents, prior returns, and all IRS correspondence. Professional advice cannot guarantee a waiver, but it can help identify the correct year, calculate the shortfall, and separate participant reporting from plan administration.

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Records and prevention for future years

After correcting the failure, create a written RMD schedule for each account. Record the account type, applicable deadline, calculation method, prior-year balance used, beneficiary designation, and the custodian’s processing lead time. Request distributions early enough to allow for holidays, address changes, transfer delays, and manual review.

At the start of each year, compare the schedule with the account statements and confirm that recurring instructions still apply after a rollover, conversion, death, beneficiary change, or custodian move. Save the confirmation when each distribution is completed. These simple records make it easier to prove that the correct amount left the correct account by the applicable deadline.

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Frequently Asked Questions

Is the 25% tax charged on my whole IRA balance?

No. The potential excise tax is calculated on the RMD shortfall—the amount that should have been distributed but was not—not on the entire account balance.

Will taking the missed RMD automatically earn the 10% rate?

No. The reduced rate depends on correcting within the applicable correction window and meeting that tax year’s reporting requirements.

Can the IRS waive the missed-RMD tax?

You may request a waiver when the shortfall resulted from reasonable error and you are taking reasonable steps to correct it. The IRS reviews the explanation and decides whether to grant some or all of the waiver.

Does my employer’s plan correction eliminate my Form 5329 filing?

No. EPCRS correction by a plan sponsor and your personal excise-tax reporting are separate obligations.

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