Proposed Trump Account Regulations Address Enrollment and Eligibility
Summary
Treasury and IRS released proposed regulations on March 9, 2026, adding enrollment and eligibility details for Trump Accounts, a new pilot IRA program for children. The $1,000 federal pilot contribution is limited to children born 2025–2028 who are U.S. citizens with an SSN and no prior pilot election on file. An annual $5,000 contribution cap applies going forward, with pilot contributions excluded from that cap.
“The proposed regulations specify that the $1,000 federal pilot contribution applies only to children born 2025–2028, who are U.S. citizens with a Social Security Number (SSN) and have no prior pilot program election on file.”
What changed
The proposed regulations confirm that the $1,000 federal pilot contribution applies only to children born 2025–2028 who are U.S. citizens with an SSN and no prior pilot election on file. Authorized individuals can open a Trump Account from SSN issuance through the end of the year the child turns 17, using Form 4547. Contributions cannot begin until July 4, 2026, with a $5,000 annual cap (including up to $2,500 from employers); pilot contributions are excluded from the cap.\n\nEmployers considering Trump Account integration face unresolved questions around ERISA exemptions, plan document requirements, and Section 125 cafeteria-plan coordination, which Treasury says it will address later. Families can open accounts when filing their 2025 federal tax return, but should monitor for additional guidance expected later in 2026.
Archived snapshot
Apr 20, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
April 20, 2026
Targeted Changes Ahead: Proposed Regulations for Trump Account Enrollment and Pilot Contribution Eligibility
LinkedIn Facebook X ;) Embed Seyfarth Synopsis: Since Trump Accounts made their debut as the “ New Kid on the IRA Block ” in December 2025, Treasury and the IRS have released proposed regulations that add important—but not always simplifying—details to the program.
The proposed regulations, released on March 9, focus heavily on pilot contribution eligibility and enrollment, adding new protections against multiple accounts being opened for the same child. Unfortunately, none of the newly proposed regulations speak to the mechanics of employer contributions to Trump Accounts.
Confirmed Designs
The proposed regulations specify that the $1,000 federal pilot contribution applies only to children born 2025–2028, who are U.S. citizens with a Social Security Number (SSN) and have no prior pilot program election on file.
Authorized individuals can elect to open a Trump Account for a child at any time from SSN issuance through the end of the year in which the child turns 17. The IRS reaffirmed the use of Form 4547 to establish a Trump Account and request the $1,000 pilot program contribution.
Trump Account contributions cannot begin until July 4, 2026. An annual $5,000 total contribution cap will apply (including up to $2,500 from employers). Importantly, the proposed regulations confirm that any pilot program contributions do not count towards the annual $5,000 limit. Investments remain limited to index funds primarily composed of U.S. equity investments.
As a reminder, Trump Account funds generally remain locked until the year the child turns 18 and will typically follow traditional IRA rules after the child turns 18 (at which point the funds can be used for a variety of qualifying purposes, including education expenses, job training, down payment on a first home, capital to start a small business, and retirement).
Administrative Questions
On April 6, 2026, Treasury announced that the Bank of New York Mellon Corporation (“BNY”) will manage initial Trump Accounts and develop an associated app. Robinhood will serve as the brokerage and initial trustee of Trump Accounts.
Otherwise, many open questions remain with respect to the establishment and administration of Trump Accounts. For employers specifically, unanswered questions include applicable ERISA exemptions, plan document requirements and coordination with Section 125 cafeteria plans—all issues Treasury says it will address at a later date.
Takeaway
The Trump administration remains committed to the Trump Account program and eligible families will have the option to open a Trump Account when submitting their 2025 federal tax return. However, many open questions remain. We expect additional guidance later this year.
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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2026
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