As the plan sponsor, you are responsible for ensuring that RMDs are met every year. This includes participants that have left the company or retired and may still have money in the plan. Failure to make required distributions is a violation of plan rules and could result in an IRS penalty and plan disqualification.
In general, 401(k) account owners don't have to take RMDs until the year they reach RMD age or retire (if allowed by the plan), whichever is later. However, account owners who own more than 5% of the business sponsoring the plan must begin taking RMDs when they reach RMD age, regardless of whether they've retired or not.
As of 2023, RMD age is 73 (previously 72). The RMD age change doesn't impact participants who had reached age 72 in 2022 or before.
RMD deadlines
RMDs for a given year generally must be taken by December 31 of that year. An account owner's first RMD, however, can be delayed until April 1 of the following year. For example: Jessica is retired and turned 72 in 2022, so she must take her RMD for 2022 by April 1, 2023. Her RMD for 2023 must also be taken by December 31, 2023.
Upcoming change for designated Roth accounts
Beginning with RMDs required for 2024 and later, designated Roth accounts will not be included in the RMD calculation. Any 2023 RMDs taken by April 1, 2024, must still include designated Roth accounts.
For more details, see the IRS RMDs page and RMDs FAQs
Answers to common questions about RMDs