U.S. Treasury and IRS Release First Proposed Regulations Implementing Trump Accounts

The U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released two proposed rulemakings on March 6, 2026, providing the first regulatory framework for Trump Accounts, the tax-advantaged savings vehicles for children created by the One Big Beautiful Bill Act in 2025. The proposals address how a Trump Account is to be opened and administered while the beneficiary is a minor and how eligible children may receive the statute’s one-time $1,000 pilot contribution.¹

The proposals provide the first operational detail for financial institutions that may serve as trustees or custodians, while leaving several core elements — such as contributions, investments, distributions, and reporting — for future rulemaking. Comments on the account-opening proposal are due May 8, 2026, and comments on the pilot-program proposal are due April 8, 2026.²

Key Takeaways

• These are the first proposed regulations implementing Trump Accounts. Treasury and the IRS have issued the first proposed regulations implementing Trump Accounts, addressing account establishment and the statute’s one-time $1,000 Treasury pilot contribution.
• Accounts must be opened as Trump Accounts from the start. Institutions must establish and title a Trump Account as such when opened. Existing IRAs cannot be converted into Trump Accounts.
• Only one funded Trump Account may exist during the growth period. The rules distinguish between an initial Trump Account and a later rollover account, which may be funded only through a full trustee-to-trustee transfer.
• Certain nonbank IRA trustees automatically qualify. Any person approved by the IRS as of December 31, 2025, to be a nonbank trustee of an IRA is automatically approved to be a nonbank trustee of a Trump Account. Persons approved by the IRS after that date must request approval to act as a Trump Account trustee, and automatically approved trustees must notify the IRS in writing if they begin serving in that capacity.
• Treasury deposits the $1,000 pilot contribution directly into the account. The contribution is not paid to families. Treasury treats the amount as a tax overpayment and refunds it directly into the child’s Trump Account.
• Major operational rules remain forthcoming. Treasury and the IRS have yet to issue comprehensive rules and guidance governing contributions, investments, distributions, reporting obligations, and coordination with traditional IRA rules.

Important Dates

• April 8, 2026: deadline to submit comments on the pilot-program contribution proposal
• May 8, 2026: deadline to submit comments on the account-opening proposal

Background

Congress created Trump Accounts in the One Big Beautiful Bill Act, enacted on July 4, 2025, by adding, among other provisions, Sections 530A, 128, and 6434 to the Internal Revenue Code.³ The accounts aim to give eligible children an early savings and investment foothold, with the goal of providing a financial head start that can grow over time through long-term investing and compounded returns.⁴ Treasury and the IRS first addressed the new regime in Notice 2025-68, issued December 2, 2025.⁵ The notice confirmed that Trump Accounts operate as a specialized form of IRA and previewed additional guidance addressing operational and reporting issues.

Recent Guidance

• December 2025 notice. Notice 2025-68 provided the first operational roadmap for Trump Accounts. Among other things, the notice confirmed that Trump Accounts are a specialized form of traditional IRA; described the statute’s growth-period framework governing contributions, investments, distributions, and reporting; and indicated that Treasury would issue additional guidance on governing instruments, rollover reporting, contribution-source tracking, and employer programs under Section 128.⁶
• Opening and administering Trump Accounts. The first proposal addresses how Trump Accounts are established and administered while the beneficiary is a minor. Institutions must establish and title the account as a Trump Account when established; an existing IRA cannot be converted into a Trump Account. The proposal distinguishes between an “initial” Trump Account and any later “rollover” account, which may be funded only through a full trustee-to-trustee transfer. As a result, during the growth period, only one funded Trump Account may exist at a time.
  
  The proposal also addresses trustee eligibility. Any person approved by the IRS as of December 31, 2025, to be a nonbank trustee of an IRA is automatically approved to be a nonbank trustee of a Trump Account. Under the proposal, a person approved by the IRS after that date is not automatically covered and instead must request approval to act as a Trump Account trustee. Any automatically approved nonbank trustee that actually begins serving as a Trump Account trustee must notify the IRS in writing.
  
  The proposal further sets rules for account-opening elections. A person may make the election using Form 4547 or an IRS electronic process and only the first processed election controls. The individual making the election generally becomes the default responsible party while the child lacks legal capacity. If no pilot-program election accompanies the opening election, the proposal applies an ordering rule for who may open the account: (1) legal guardian, (2) parent, (3) adult sibling, (4) grandparent.⁷
• Pilot program contribution. A separate proposal explains how eligible children receive the statute’s one-time $1,000 Treasury pilot contribution. The pilot program generally applies to U.S.-citizen children born between 2025 and 2028 who have Social Security numbers and who have not already received the contribution. An individual may request the contribution if that person expects the child to be the individual’s qualifying child for the relevant taxable year. As with account-opening elections, only the first processed election results in the contribution. Treasury will deposit the $1,000 directly into the child’s Trump Account. The proposal treats the payment as a tax overpayment refunded directly into the account and protects it from certain offsets.⁸

Issues Reserved for Future Guidance

The proposals address account establishment and the pilot contribution but leave many operational issues unresolved. Treasury and the IRS have expressly reserved guidance on issues including:

• contributions rules during the growth period
• permitted investments
• distribution mechanics
• reporting requirements
• coordination with ordinary IRA rules

Notice 2025-68 likewise indicates that additional guidance will address governing instruments, contribution tracking, rollover reporting, and other operational matters.⁹

Implications for Financial Institutions

Beyond account establishment and trustee eligibility, institutions still lack the full servicing framework needed to implement Trump Accounts. Financial institutions considering participation should monitor forthcoming Treasury and IRS guidance, evaluate whether they intend to serve as trustees or custodians, and confirm whether they qualify for automatic approval as nonbank trustees under the proposed rules.

Institutions that qualify should also prepare to notify the IRS in writing if and when they begin serving as Trump Account trustees.

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Sidley is closely monitoring developments related to Trump Accounts. Please contact us if you have any questions or would like assistance in navigating current and forthcoming guidance related to Trump accounts.

1 Trump Accounts, 91 Fed. Reg. 11,194 (proposed Mar. 9, 2026) (to be codified at 26 C.F.R. pt. 1) (comments due May 8, 2026); Trump Accounts Contribution Pilot Program, 91 Fed. Reg. 11,203 (proposed Mar. 9, 2026) (to be codified at 26 C.F.R. pt. 301) (comments due Apr. 8, 2026).
2 Trump Accounts, 91 Fed. Reg. at 11,194; Trump Accounts Contribution Pilot Program, 91 Fed. Reg. at 11,203. 
3 An Act to Provide for Reconciliation Pursuant to Title II of H. Con. Res. 14, Pub. L. No. 119-21 (2025); Trump Accounts, 91 Fed. Reg. 11,194 (proposed Mar. 9, 2026); Trump Accounts Contribution Pilot Program, 91 Fed. Reg. 11,203 (proposed Mar. 9, 2026).
4 Trump Accounts, I.R.S. (last updated Dec. 4, 2025); Trump Accounts Give the Next Generation a Jump Start on Saving, White House (Aug. 29, 2025); Trump Accounts Will Chart the Path to Prosperity for a Generation of American Kids, White House (June 9, 2025).
5 Notice of Intent to Issue Regulations with Respect to Section 530A Trump Accounts, I.R.S. Notice 2025-68, 2025-52 I.R.B. 856.
6 Id. 
7 Trump Accounts, 91 Fed. Reg. at 11,195–98, 11,200–03.
8 Trump Accounts Contribution Pilot Program, 91 Fed. Reg. at 11,205–08, 11,212.
9 Trump Accounts, 91 Fed. Reg. at 11,196, 11,198; Notice 2025-68, 2025-52 I.R.B. 856.