Can you delay IRA RMDs while still working?

No. The still-working exception applies only to employer-sponsored plans (401k, 403b, governmental 457b) for your current employer. Traditional IRAs, SEP IRAs, and SIMPLE IRAs require RMDs starting at age 73 regardless of your employment status.

What happens to 401(k) RMDs when you retire after age 73?

Once you separate from service, you must begin taking RMDs from the 401(k). The first RMD after retirement is due by April 1 of the year following your retirement year (or December 31 of the retirement year if you prefer to avoid doubling up). Normal RMD calculations apply using the December 31 prior-year balance.

Does the 5% owner rule affect spouses or family members?

The 5% ownership test uses IRS attribution rules, which may include ownership held by a spouse or certain family members. If you collectively own more than 5% through family attribution, the still-working exception may not apply. Consult a tax professional if you have complex ownership situations.

Does the still-working exception apply to a 403(b) or 457(b) plan?

Yes. The still-working exception applies to 403(b) plans for public school employees and non-profit workers, and to governmental 457(b) plans. Non-governmental 457(b) plans have different rules. As with 401(k)s, only the current employer's plan qualifies — old 403(b) or 457(b) balances from previous employers require RMDs at the normal age.

What happens if you retire and then return to work at the same employer?

If you separated from service, began RMDs, and then were rehired by the same employer, the IRS does not allow you to stop previously-required RMDs. The still-working exception is evaluated at separation from service. Re-employment at the same employer after RMDs began does not retroactively restore the exception.

Scenario

RMD Still-Working Exception — Can You Delay 401(k) RMDs If You're Employed?

Can you delay Required Minimum Distributions if you are still working past age 73?

If you are still employed at age 73 or beyond, you may be able to delay Required Minimum Distributions from your current employer's 401(k), 403(b), or governmental 457(b) plan. This is the "still-working exception" — a significant planning opportunity for those who continue working into their 70s.

The exception only applies to the current employer's plan. Traditional IRAs, old employer 401(k)s, and SEP or SIMPLE IRAs still require RMDs at the normal age regardless of employment status. If you want to consolidate old 401(k)s and avoid their RMDs, rolling them into your current employer's plan (if the plan accepts rollovers) can extend the delay.

Key RMD Rules

1Still-working exception applies only to the current employer's qualified plan (401k, 403b, governmental 457b).
25% ownership rule: if you own more than 5% of the business, the exception does not apply — RMDs are required even if still working.
3IRAs (traditional, SEP, SIMPLE): still-working exception does NOT apply. RMDs start at normal age.
4Old employer plans (former employer 401k): still-working exception does NOT apply.
5If you roll an old 401(k) into the current employer's plan (if plan accepts rollovers), those funds may qualify for the delay.
6Once you separate from service, RMDs must start by the following April 1.

Does the Still-Working Exception Apply to You?

Answer these three questions: (1) Are you currently employed at the company that sponsors the 401(k)? If yes to all that follow, you may qualify. (2) Do you own 5% or less of the company? If you own more than 5%, the exception does not apply. (3) Does the plan document allow the delay? Some plans opt out — check with HR or the plan administrator.

Strategy: Rolling Old 401(k)s Into the Current Plan

If your current employer's 401(k) plan accepts incoming rollovers, you can roll old employer plan balances into the current plan. Those rolled-over balances may then also qualify for the still-working exception, delaying RMDs on those funds as well. Not all plans accept rollovers — confirm with the plan administrator before initiating a rollover.

Common RMD Mistakes to Avoid

⚠Assuming the still-working exception applies to IRAs — it does not. IRA RMDs begin at 73 regardless of employment.
⚠Assuming it applies to old employer plans — the exception covers only the current employer's active plan.
⚠Business owners over 5%: the exception does not apply. If you own more than 5% of the business sponsoring the plan, you must start RMDs at 73 even if still working.

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Frequently Asked Questions

Disclaimer: This content is for informational purposes only and does not constitute tax or financial advice. RMD rules are based on IRS Publication 590-B and SECURE 2.0 Act provisions. Always consult a qualified tax professional or financial advisor for guidance specific to your situation. IRS rules may change; verify current requirements at irs.gov.

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