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RMD aggregation across IRAs vs 401(k)s: what you can combine

RMD aggregation across IRAs vs 401(k)s: what you can combine, what you must take from each plan, and a worked example with multiple custodians.

Once required minimum distributions (RMDs) begin, the IRS does not treat every retirement account the same way. You can often aggregate traditional IRA RMDs and take the total from one or more IRAs. 403(b) RMDs can likewise be aggregated across 403(b) contracts and taken from one or more of them. 401(k) RMDs generally must be calculated and satisfied per plan. First-year timing: Required beginning date for RMDs. Account map: Roth IRA vs 401(k) starter.

This page is aggregation, not the full RMD age or table guide.

What usually aggregates (orientation)

Account typeTypical aggregation rule
Traditional IRAs (including SEP and SIMPLE IRAs you own)Calculate an RMD for each IRA, then you may total them and withdraw that sum from one or more of your IRAs
Employer 401(k) plansRMD generally calculated separately for each plan; take from that plan (you usually cannot satisfy a 401(k) RMD from an IRA)
403(b) contractsCalculate an RMD for each 403(b), then you may total them and withdraw that sum from one or more 403(b)s (IRA-like aggregation; still separate from IRAs and 401(k)s)
Roth IRA (original owner)No lifetime RMDs under current rules, do not mix into traditional IRA aggregation math
Inherited IRAsOften different schedules (Inherited IRA 10-year rule); do not casually aggregate with your own IRA RMDs
Still-working 401(k) at current employerPlan may allow delay; that delay does not pause IRA RMDs

Custodians such as Fidelity, Vanguard, Schwab, and workplace recordkeepers often show a suggested RMD per account. They may not know your other IRAs. You remain responsible for the combined IRA total and for taking each plan’s workplace RMD correctly.

Worked example: two IRAs and one 401(k)

Morgan is subject to RMDs. Prior year-end balances and illustrative factors:

AccountDec 31 balanceIllustrative factorAccount RMD
Traditional IRA at Vanguard$300,00025.6$11,719
Traditional IRA at Fidelity$180,00025.6$7,031
Former-employer 401(k) at Empower$220,00025.6$8,594
  • IRA aggregation: Morgan must take at least $11,719 + $7,031 = $18,750 from traditional IRAs. Morgan may take the full $18,750 from the Vanguard IRA alone, or split across both IRAs. Morgan may not take that IRA total from the 401(k) instead.
  • 401(k): Morgan must still take at least $8,594 from the Empower 401(k). That current-year RMD amount is not eligible for rollover; only the remaining eligible balance after the RMD can be rolled to an IRA.
  • Wrong move: Taking $27,344 only from the Vanguard IRA and $0 from Empower does not satisfy the 401(k) RMD.

Tax reporting still lands on Forms 1099-R for filing season (Filing taxes for beginners). Eligible charitably inclined owners may route some IRA dollars as qualified charitable distributions (QCDs) when rules allow, QCDs do not automatically fix a missed 401(k) RMD.

Practical habits

  1. Inventory every traditional IRA, SEP, SIMPLE, 401(k), and 403(b) before November.
  2. Sum IRA RMDs; decide which IRA(s) will pay them.
  3. Calendar each workplace plan’s RMD separately.
  4. Do not assume a custodian auto-RMD knows your other firms.
  5. After Roth conversions or rollovers, review mid-year which accounts still need their RMD and what you have already distributed. The year’s RMD is still based on prior Dec 31 balances; a conversion or rollover does not rewrite that starting math.
  6. Keep inherited accounts on their own schedule.

Checklist

  1. List every tax-deferred account and custodian.
  2. Compute each IRA RMD, then one IRA total you will actually withdraw.
  3. Compute each 401(k) RMD per plan; aggregate 403(b) RMDs only with other 403(b)s.
  4. Confirm first-year RBD timing if this is year one.
  5. Set withholding or estimates; archive 1099-R forms.
  6. Revisit after job changes, rollovers, or conversions.

Educational only. Not tax, legal, or investment advice. Aggregation rules, 403(b) nuances, Roth employer-plan RMDs, and penalties change; confirm with current IRS publications, plan documents, and a qualified tax professional.