RMD Aggregation Rules

The IRS allows you to aggregate—combine—the required minimum distributions (RMDs) from multiple retirement accounts when calculating how much you must withdraw each year, but the rules differ sharply between IRAs and workplace plans. Understanding which accounts can be pooled and which require separate annual withdrawals is essential for tax-efficient retirements.

What aggregation means

When you turn 73 (or 72 if you reached that age before 2023), the IRS requires you to withdraw a minimum percentage of your retirement account balances each year. Rather than take the required amount from each account individually, aggregation lets you calculate the total RMD across multiple accounts and withdraw it from just one—or split it however you wish among the accounts in the aggregation group.

The upshot: fewer withdrawals, simpler paperwork, and more control over which account funds the distribution.

IRAs and the aggregation rule

The IRS permits you to aggregate RMDs from all of your IRAs—traditional, SEP, and SIMPLE combined—for the purpose of calculating your annual withdrawal requirement. You compute the total RMD across all IRAs, then take that amount from whichever IRA (or IRAs) you choose.

This flexibility is powerful. If you have a Traditional IRA worth $500,000 and a SEP IRA worth $200,000, the combined RMD might be $21,000. You could withdraw the entire $21,000 from the Traditional IRA, leaving the SEP untouched, or split it any way you like. The IRS doesn’t care which account the money comes from, as long as the total distribution equals or exceeds the combined RMD.

Roth IRAs are excluded from this aggregation—they carry no RMD during the original owner’s lifetime. However, if you inherit a Roth IRA, those RMDs may be required and can sometimes be aggregated with inherited traditional IRAs from the same source (depending on the beneficiary and the year of death).

Workplace plans: separate account, separate distribution

The rules tighten considerably for 401(k)s, 403(b)s, 457(b)s, and similar workplace plans. Each must be treated as a separate account for RMD purposes. You cannot aggregate a 401(k) and a 403(b), and you cannot combine either with an IRA.

This means if you have a 401(k) through a current employer and a 403(b) from a previous job, you must calculate the RMD for each and ensure that each distribution comes from its respective plan. The money must leave the plan account itself; you cannot satisfy a 401(k) RMD by withdrawing from an IRA, even if the combined IRA RMD is larger.

There is one partial exception: if you are no longer employed at a company and have rolled a 401(k) or 403(b) into a traditional IRA, that rolled-over money now lives in an IRA and can be aggregated with your other IRAs. But while the plan is active or held in a separate plan account, the separation rule applies.

The aggregation calculation in practice

Suppose you have three accounts: a Traditional IRA ($300,000), a SEP IRA ($200,000), and a 401(k) ($250,000). All balances are measured as of December 31 of the prior year. Your age is 75.

• IRAs aggregated: Traditional ($300,000) + SEP ($200,000) = $500,000. Using the IRS life expectancy table, the RMD factor for age 75 is approximately 24.6. RMD = $500,000 ÷ 24.6 ≈ $20,325.
• 401(k) separate: $250,000 ÷ 24.6 ≈ $10,163.

Total required: $20,325 (from IRAs) + $10,163 (from the 401(k)) = $30,488.

For the IRA portion, you withdraw $20,325 from either the Traditional IRA, the SEP, or a combination of both. For the 401(k), you must withdraw $10,163 from the 401(k) itself. You cannot move the $10,163 requirement to an IRA.

Multiple employers: special rule for in-service withdrawals

Some 401(k) plans allow in-service distributions—withdrawals before age 59½ or retirement—and some employers offer multiple 401(k) plans. The aggregation rule does not apply: each plan’s RMD must be calculated and withdrawn separately, even if you work for the same employer.

Why aggregation matters

Aggregation reduces administrative burden and gives you control over account sequencing. If one IRA holds cash but another holds illiquid securities, you can take your RMD from the liquid account without being forced to liquidate positions. It also matters for tax planning: you might prefer to keep a tax-deferred account intact longer and draw the RMD from a lower-growth fund.

However, aggregation does not reduce your total RMD obligation—only how you allocate it among accounts. Missing even a single aggregated withdrawal triggers a 25% penalty (reduced from 50% under the SECURE 2.0 Act) on the shortfall, so accuracy is critical.

See also