What Should You Do If You Miss an RMD?

Ross Marino |

You review a year-end statement, tax organizer, or account history and realize a required minimum distribution was missed—or the amount withdrawn was too small. The discovery can feel alarming because the deadline has passed and an excise tax may apply.

A missed RMD is not something to ignore, but it is often a correctable filing problem. The useful response is a sequence: verify the obligation, measure the shortfall, take the missing distribution, preserve the facts, and use the correct tax-year Form 5329 to report the result or request relief.

How much of the RMD was actually missed?

Begin with the RMD that applied to the specific account for the missed year. The calculation generally starts with the prior December 31 balance and the applicable IRS life-expectancy factor, but inherited accounts, a spouse more than 10 years younger, workplace plans, and a first RMD year can change the analysis.1

Then compare the required amount with distributions that counted by the deadline. Traditional IRAs can generally be aggregated for withdrawal purposes after each IRA's RMD is calculated separately. Most employer plans cannot be combined with other plans; 403(b) accounts have their own aggregation rule. A distribution from the wrong account may therefore leave a shortfall even if enough money left retirement accounts overall.2

What should happen as soon as the shortfall is known?

If an amount remains unpaid, arrange a distribution from the account that owed it as soon as practical. A late withdrawal does not retroactively meet the original deadline, but it demonstrates that the shortfall is being remedied and may help satisfy either the reduced-tax rules or a reasonable-cause waiver request. Keep the confirmation showing the account, amount, request date, and payment date.

One repair path, then two possible filing outcomes

The corrective work comes first. The tax result is evaluated only after the shortfall and response are known.

Measure

Required amount − qualifying distributions = shortfall

Correct

Take the remaining distribution from the account that owed it.

Document

Preserve the cause, correction dates, and proof of the repair.

The same completed repair supports either branch ↓

Reasonable cause applies

File the missed year’s Form 5329 and request a waiver with the explanation.

Waiver is not requested or granted

Use the applicable Form 5329 to determine whether the 10% or 25% tax remains.

What documentation supports reasonable cause?

The IRS may waive part or all of the excise tax when the shortfall resulted from reasonable error and reasonable steps are being taken to remedy it. The explanation should be factual and specific: what happened, why it happened, when it was discovered, when the distribution was corrected, and what changed to reduce the chance of recurrence.3

Useful records may include custodian correspondence, proof of the corrective distribution, notices of illness or incapacity, evidence of an administrative mistake, and the calculation used to identify the shortfall. The goal is not a long narrative. It is a coherent record connecting the error to the repair.

Dovetail Principle: Financial Decisions Need to Fit Together

The first decision is not whether the IRS will waive the tax. It is how to measure and correct the missed distribution. Prompt repair creates the facts needed to evaluate the tax and make a credible relief request.

Does the 25% or 10% excise tax apply?

The current default excise-tax rate on an RMD shortfall is 25%. It can be reduced to 10% if, during the statutory correction window, the shortfall is distributed from the plan involved and a return reflecting the additional tax is submitted. The window ends at the earliest of an IRS deficiency notice, assessment of the tax, or the last day of the second taxable year beginning after the year of the missed RMD.4

That rate comparison matters only for tax not waived. A taxpayer who qualifies for reasonable-cause relief can ask the IRS to waive the amount attributable to the stated shortfall. The IRS, not the taxpayer or custodian, decides whether to grant the request.

How is the missed RMD reported now?

Use the Form 5329 for the tax year in which the RMD was missed—not simply the newest form. On the 2025 form, Part IX uses lines 52a–55. For a waiver request, complete the required and actual distribution lines, write “RC” and the requested waiver amount in parentheses next to line 54a or 54b, reduce the reported shortfall by that requested amount, and attach the explanation. Pay any tax remaining on line 55. Line numbers can change, so follow the instructions for the applicable year.5

If no return was otherwise required for that year and no other changes are needed, Form 5329 may generally be filed by itself; a stand-alone Form 5329 must be signed and mailed. If other items on an already-filed return must change, the prior-year Form 5329 is generally filed with Form 1040-X. Married spouses with their own filing obligations complete separate Forms 5329.6

Close the loop by confirming every account subject to an RMD, who calculates it, which account will fund it, and whether automatic distributions are appropriate. Also review withholding, charitable distributions, and inherited-account deadlines separately. The recovery is complete when the prior error is addressed and the next deadline has an owner.

A missed RMD is a time-sensitive tax matter, but it does not require panic. Accurate reconstruction, prompt correction, disciplined documentation, and the correct filing sequence turn an unsettling discovery into a manageable recovery decision.

For a wider view of how required withdrawals fit into the retirement plan, continue with How Should You Plan RMDs Across Multiple Retirement Accounts?

About the author

Ross Marino, CFP®, CeFT®, is the Founder & CEO of Dovetail Financial and creator of Human-First Financial Guidance®. He helps people nearing or living in retirement connect their lives and wealth so that financial decisions become clearer, more personal, and easier to navigate.

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Notes

  1. Internal Revenue Service, Publication 590-B (2025), Distributions from Individual Retirement Arrangements.
  2. Fidelity, Required minimum distributions: What you need to know.
  3. Schwab, Missed an RMD? Here's What to Do.
  4. Tax Foundation, SECURE 2.0 Act: Changes to Retirement Tax Provisions.
  5. Internal Revenue Service, 2025 Instructions for Form 5329.
  6. AARP, What Happens If You Miss Your RMD?.

Disclosure

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