Do You Have to Take Annual RMDs During the 10-Year Rule? It Depends on One Date

Guides · Updated October 2026

This is the question that tripped up beneficiaries, and frankly a lot of tax professionals, for years after the SECURE Act passed. The 10-year rule says you must empty an inherited IRA by December 31 of the tenth year after the owner's death. Simple enough. But do you also have to take a required minimum distribution every year along the way, or can you wait until year 10 and take it all at once? The IRS finally settled it in final regulations published in July 2024, and the answer hinges on a single date: whether the original owner died before or after their required beginning date.

The one date that decides everything

The required beginning date, or RBD, is the deadline by which the original account owner had to start taking their own RMDs. Under SECURE 2.0, that is generally April 1 of the year after turning 73 (age 75 for those born in 1960 or later). Everything about your annual RMD obligation flows from which side of that date the owner died on.

Owner died BEFORE the required beginning date: no annual RMDs

You do not have to take distributions in years 1 through 9. You have complete flexibility over timing, as long as the account is fully emptied by December 31 of year 10. Take it all in year 3, spread it evenly, or wait until year 10. The IRS does not care, though your tax bill certainly will, which is a separate planning question.

Owner died ON OR AFTER the required beginning date: annual RMDs required

You must take annual RMDs in years 1 through 9, calculated from your own life expectancy, and still empty the entire account by the end of year 10. This is the "both" scenario people miss: the annual distributions do not satisfy the 10-year deadline by themselves, because life expectancy RMDs are small. Year 10 still requires a final distribution of whatever remains.

A concrete example

Sandra's situation: her father died in 2022 at age 76, leaving her a traditional IRA. Age 76 is past the required beginning date, so Sandra owes annual RMDs for 2023 through 2031, and must empty the account completely by December 31, 2032.

Each year's RMD equals the prior year-end balance divided by her life expectancy factor from IRS Publication 590-B Table I, reduced by 1 each year. If Sandra was 48 in 2023, her starting factor is 38.1. On a $300,000 balance, her first RMD is roughly $7,874. Small, but mandatory, and missing it triggers the penalty below.

The waiver years: 2021 through 2024

Here is a wrinkle worth knowing. While the IRS was sorting out the rules, it waived penalties for missed annual RMDs from 2021 through 2024. That grace period is over: starting with 2025, the annual RMDs are enforceable. But critically, the waived years still count toward your 10-year window. The clock was never paused. If the owner died in 2021, your deadline is still December 31, 2031, whether or not you took distributions in the waiver years. I have seen beneficiaries assume the waivers bought them extra time. They did not.

The Roth exception

Inherited Roth IRAs get the friendlier branch automatically. A Roth owner never has a required beginning date, because Roth owners never take lifetime RMDs, so every Roth owner is treated as dying before that date. Result: no annual RMDs in years 1 through 9, just the year-10 deadline, and qualified distributions are income tax free. The common strategy is to let an inherited Roth grow untouched for most of the window and withdraw near the end.

The penalty for getting this wrong: missing a required distribution triggers a 25 percent excise tax on the shortfall. If you correct the mistake within two years, the rate drops to 10 percent. Either way, it is an avoidable hit. If you think you missed an annual RMD, take the missed amount as soon as you discover the error and talk to your tax preparer about reporting it properly. Ignoring it is the worst option.

How to figure out which camp you are in

Three questions, in order:

Did the owner die in 2020 or later? If before 2020, the old stretch rules may apply instead. This guide covers 2020 and later.
How old was the owner at death? Under 73 (or under 75 if born in 1960 or later) generally means before the required beginning date: no annual RMDs. At or above it: annual RMDs apply. Roth accounts skip this question entirely.
Are you an eligible designated beneficiary? Surviving spouses, minor children of the owner, disabled or chronically ill individuals, and beneficiaries not more than 10 years younger than the owner follow different rules, usually the life expectancy method with no 10-year deadline.

If you are a non-spouse beneficiary subject to the 10-year rule and the owner died on or after the required beginning date, you are in the annual RMD camp. Run your numbers through our calculator to see the year by year schedule with the exact factors.

See your personal distribution schedule.

Which rule applies to you, annual RMD amounts, and key deadlines.

Run your own numbers with the free calculator

Frequently asked questions

Do the annual RMDs count toward emptying the account by year 10?

Yes, every distribution reduces the balance, but annual RMDs are calculated to stretch over your life expectancy, so they are far too small to empty the account on their own. You will still face a significant final distribution in year 10. Plan for it rather than being surprised by it.

What if the owner died exactly at age 73?

What matters is whether the owner died on or after their required beginning date, which is April 1 of the year after turning 73 (not the 73rd birthday itself). If the owner died after that April 1 date, annual RMDs apply. This is an edge case worth confirming with a tax professional, because the exact date controls the outcome.

Can I take more than the annual RMD?

Absolutely. The annual RMD is a minimum, not a maximum. Many beneficiaries deliberately take more than required in lower income years to shrink the year-10 lump sum and stay in a lower tax bracket. See our guide to spreading distributions across the 10-year window.

Does the 10-year rule apply to inherited 401(k)s too?

Yes. The rule covers inherited IRAs, 401(k)s, 403(b)s, and other defined contribution accounts, not just traditional IRAs. The same before-or-after required beginning date test determines whether annual RMDs apply.