2026 Trump Accounts Go Live

At A Glance

• Trump Accounts launched on July 4, 2026.
• Recent DOL guidance confirms that Trump Accounts are not subject to ERISA.

Introduction

Effective July 4, 2026, the Trump Accounts program allows eligible accounts to accept contributions and qualifying children to receive the federal $1,000 pilot contribution. These tax-advantaged investment accounts for minors under age 18 have a $5,000 annual contribution limit from all sources, including up to $2,500 from employers. Eligible children born between 2025 and 2028 may receive a one-time $1,000 federal contribution if required elections are made. Funds are generally restricted until age 18, when the account is converted to a traditional IRA.

While federal agencies have issued some preliminary guidance, including recent Department of Labor guidance addressing certain ERISA considerations, important questions remain regarding the practical administration of these accounts. Specifically, additional regulatory guidance is still needed concerning:

• Employer contribution program requirements and implementation;
• Operational and administrative mechanics for employers and service providers;
• Payroll integration and reporting processes; and
• Other compliance and recordkeeping obligations associated with account contributions. 

Organizations considering offering employer contributions should be aware that the regulatory framework is still evolving. Employers should continue to monitor future guidance from the Treasury Department, IRS, and Department of Labor before finalizing program design or implementation decisions.