In short: 401(k) RMDs can't be aggregated — each plan requires its own separate distribution. If you're still employed by the plan sponsor (and don't own 5%+), you may delay RMDs from that plan until retirement. Rolling an old 401(k) into an IRA simplifies things long-term but eliminates the still-working exception and requires you to take the current year's RMD first.
On this page
- The No-Aggregation Rule
- The Still-Working Exception
- Rolling a 401(k) into an IRA: What to Consider
- Roth 401(k) Accounts
- How 401(k) RMDs Are Calculated
- A Real Example
- What to Do Next
Required Minimum Distributions from a 401(k) follow the same basic formula as IRA RMDs — prior year-end balance divided by an IRS life expectancy factor. But three things work differently, and each one can cost you money if you don't know about it.
First, you cannot aggregate 401(k) RMDs. Each account requires its own separate distribution. Second, if you're still working for the employer that sponsors the plan, you may be able to delay RMDs from that specific 401(k) until you retire. Third, rolling a 401(k) into an IRA before taking the RMD can trigger a problem most people don't see coming.
This page covers what's different. For the general rules that apply to all account types, see: RMD rules by account type
401(k) vs. IRA: Three Key Differences
The No-Aggregation Rule
If you're used to managing IRAs, this is the rule that will catch you off guard. It's the single most common 401(k) RMD mistake we see.
With Traditional IRAs, you can calculate the total RMD across all your IRAs and then withdraw the full amount from whichever account you choose. The IRS allows this because all Traditional IRAs are treated as one pool for RMD purposes.
401(k)s don't work that way. Each 401(k) is a separate plan with its own RMD, and you must satisfy each one individually. You can't take a larger amount from one to cover both, and you can't take an IRA distribution to satisfy a 401(k) RMD, or vice versa.
| Account Type | Can You Aggregate RMDs? |
|---|---|
| Traditional IRAs | Yes — calculate total, withdraw from any one or combination |
| 401(k) plans | No — each plan requires its own separate distribution |
| 403(b) plans | Yes — can aggregate across 403(b) accounts (but not with IRAs or 401(k)s) |
If you have multiple 401(k)s from past employers, it may be worth consolidating them into a single IRA to simplify future RMDs. But read the next two sections before doing that — the still-working exception and the rollover timing rule both matter.
The Still-Working Exception
If you're 73 or older and still employed, you may be able to delay RMDs from your current employer's 401(k) until the year you actually retire. This is sometimes called the "still-working exception" or "still-employed exception."
The rules are specific:
You qualify if you are still working for the employer that sponsors the 401(k), the plan document allows this delay (most large plans do, but not all), and you do not own 5% or more of the company.
You don't qualify if the 401(k) is from a former employer (even if you haven't rolled it over yet), you own 5% or more of the business, or the plan document doesn't permit the delay.
This exception applies only to the current employer's plan. It does not extend to IRAs, 401(k)s from previous employers, or any other retirement account. If you have a Traditional IRA and a current-employer 401(k), you still need to take RMDs from the IRA on schedule — only the current employer's plan is eligible for delay.
The exception ends in the calendar year you retire. Your first RMD from that plan is due by April 1 of the year after retirement (the same first-year rule that applies to everyone else). See: First-year RMD rules
If you're not sure whether your plan allows this delay, ask your HR department or plan administrator before relying on it. I've talked to people who assumed they qualified, only to find out their plan document didn't include the provision. Don't assume — get it in writing.
Source: IRS — Retirement Topics: Required Minimum Distributions
Rolling a 401(k) into an IRA: What to Consider
Consolidating old 401(k)s into a single Traditional IRA is one of the most common pieces of retirement advice — and for RMD purposes, it has real advantages. You go from managing separate distributions from each plan to calculating one total IRA RMD and taking it from whichever account you prefer.
But the timing matters, and there's one scenario where a rollover can backfire.
The RMD-first rule: If you're already subject to RMDs, you must take the current year's RMD from the 401(k) before rolling over the remaining balance. The RMD portion is not eligible for rollover — period. If you roll over the full balance without first taking the RMD, the IRS treats that RMD amount as an excess contribution to the IRA, which triggers a separate 6% annual penalty on the excess until it's corrected. Get the sequencing right: RMD out first, then rollover.
The still-working exception disappears: If you roll a current employer's 401(k) into an IRA while still working, those funds immediately become subject to IRA RMD rules. You lose the still-working exception for that money. This matters if you're 73+ and planning to work for several more years.
The simplification payoff: Once the rollover is complete and the RMD-first rule is satisfied, your future life gets simpler. One account type, one aggregation pool, one distribution to manage. For most people with old 401(k)s sitting at former employers, this is the right long-term move — just handle the sequencing correctly.
Talk to your plan administrator about your 401(k)'s rollover process, and confirm with your CPA that the RMD for the current year has been satisfied before initiating the transfer.
Roth 401(k) Accounts
Designated Roth accounts in employer plans — Roth 401(k)s and Roth 403(b)s — are no longer subject to RMDs during the original owner's lifetime. The SECURE 2.0 Act eliminated this requirement starting in 2024.
Before 2024, Roth 401(k) owners were required to take RMDs even though the distributions were tax-free. That rule no longer applies. If you have a Roth 401(k), you can leave it in the plan indefinitely without taking distributions.
However, beneficiaries who inherit a Roth 401(k) are still subject to distribution rules. Non-spouse beneficiaries generally must follow the 10-year rule — the account must be fully emptied within 10 years of the original owner's death. Spouse beneficiaries have additional options. For more on this: Roth IRA RMD rules
How 401(k) RMDs Are Calculated
The formula is the same as for IRAs:
RMD = Prior year-end account balance (Dec. 31) ÷ IRS life expectancy factor
Most 401(k) account owners use the Uniform Lifetime Table, unless their sole beneficiary is a spouse who is more than 10 years younger — in which case the Joint Life and Last Survivor Table applies, producing a smaller RMD.
Your plan administrator or custodian should be able to provide your December 31 account balance. Some plans calculate the RMD for you, but verify the number independently — the responsibility for taking the correct amount is yours.
For a walkthrough of the tables and how the factor works: RMD tables explained
Calculate your 401(k) RMD now — free, no account required.
A Real Example
Tom is 74. He has three retirement accounts:
- A Traditional IRA at Vanguard (balance: $310,000)
- An old 401(k) from a previous employer at Fidelity (balance: $185,000)
- A current-employer 401(k) at his company's plan through Empower (balance: $220,000)
Tom is still working full-time and doesn't own 5% or more of the company. His plan document allows the still-working exception.
Here's what Tom owes this year:
| Account | Balance (Dec. 31) | Factor (age 74) | RMD | Action |
|---|---|---|---|---|
| Traditional IRA (Vanguard) | $310,000 | 23.8 | $13,025 | Must take by Dec 31 |
| Old 401(k) (Fidelity) | $185,000 | 23.8 | $7,773 | Must take by Dec 31 — separate distribution |
| Current 401(k) (Empower) | $220,000 | 23.8 | $0 (deferred) | Still-working exception applies |
Tom must take $13,025 from his IRA and $7,773 from his old Fidelity 401(k) — separately. He cannot combine them. His current employer's 401(k) is deferred until the year he retires.
If Tom wanted to simplify, he could roll the old Fidelity 401(k) into his Vanguard IRA — but only after taking the $7,773 RMD from it first. Skipping that step would make the RMD amount an excess IRA contribution. Next year, he'd have one IRA RMD to manage instead of two separate distributions. His current-employer 401(k) stays put — rolling it over while still working would eliminate his deferral.
Track multiple accounts and export CPA-ready reports — SimpleRMD handles the math across account types.
What to Do Next
- Run the calculator — free, no account required. Works for 401(k)s and IRAs.
- RMD rules by account type — how RMDs work across Traditional IRAs, SEP IRAs, Roth accounts, annuities, and more.
- When do RMDs start? — age 73 vs. 75, the still-working exception, and first-year timing.
- RMD tables explained — how the IRS life expectancy factor works.
- How SimpleRMD works — track multiple accounts, get deadline reminders, and export CPA-ready reports.
This article is for informational purposes only and does not constitute tax, legal, or financial advice. IRS rules and tax laws are subject to change. Consult a qualified tax professional or financial advisor for guidance specific to your situation. SimpleRMD is a calculation and tracking tool — not a financial advisory service.
Sources: IRS.gov (Publication 590-B, Pub 590-B PDF, Retirement Topics: RMDs, RMD FAQs). SECURE 2.0 Act of 2022 (Pub. L. 117-328), Section 107 (Roth employer plan RMDs), Section 325 (reduced excise tax). Rules confirmed current as of February 2026.