Employers can contribute to Trump accounts starting in July 

These accounts can only be established for the exclusive benefit of individuals who already have a social security number and will not attain the age of 18 before the end of the calendar year. Under the proposed regulations, the person authorized to open an initial Trump account for an eligible individual would depend on whether an election is being made at the same time to receive the pilot program contribution:

• If the pilot program contribution is not being elected, then an “authorized individual” in the following order of priority could establish a Trump account: the eligible individual’s legal guardian, parent, adult sibling, or grandparent.
• If the election to establish the initial account is made at the same time as an election to receive a pilot program contribution, the election may be made only by a “pilot program-electing individual,” that is, an individual who anticipates that the eligible individual will be their “qualifying child” under IRC Section 152(c) for tax purposes in the tax year the election is being made. (A five-part test determines whether an individual is a qualifying child, and a qualifying child needn’t actually be the individual’s child, but may be a grandchild, sibling, or the child of a sibling in some cases.)

The election to establish an initial Trump account is made using Form 4547, Trump Account Election(s) at any time by the end of the calendar year in which the eligible individual turns 18, or may be made at trumpaccounts.gov. The Secretary of Treasury will create or organize the initial Trump account for each eligible individual following the authorized individual’s election. The proposed regulations say the individual who elects to establish the initial Trump account would be responsible for managing the account during the growth period, although the trustee’s account agreement or state law could specify a different individual.

After the initial account is opened, a “rollover Trump account” could be established with a different trustee during the growth period. The rollover account would first have to be funded by a “qualified rollover contribution” (i.e., a trustee-to-trustee transfer of the entire account balance from the eligible individual’s existing account) before it could receive any other contributions. Eligible individuals may only have one funded account at any time.

The account trustee must be a bank (as defined in IRC Section 408(n)) or a nonbank trustee approved by the IRS. Any person the IRS has already approved to be a nonbank trustee of an IRA as of December 31, 2025, is automatically approved.

Accounts can begin receiving contributions on July 4, 2026 (i.e., 12 months after the law’s enactment) and can continue receiving contributions through the end of the growth period. Five types of contributions can be made to an account during the growth period:

• A $1,000 federal government contribution under a pilot program for US-citizen children born from 2025 through 2028
• “Qualified general contributions” by the federal government or certain governmental or nonprofit entities to a qualified class of beneficiaries
• Qualified rollover contributions from another Trump account
• Employer contributions to the account of an employee’s dependent child under age 18 or the account of an employee who is under 18
• Contributions from any other source (e.g., the account beneficiary, their parents, or guardians)

Contributions by individuals and employers are subject to an aggregate $5,000 per year contribution limit (indexed for inflation after 2027). The federal government’s pilot program contribution, qualified general contributions, and qualified rollover contributions don’t count toward the limit. Notice 2025-68 says the trustee is responsible for ensuring aggregate individual and employer contributions don’t exceed the annual limit.

Individuals can’t take a tax deduction for contributions, and contributions aren’t included in the account beneficiary’s income when made. Although a Trump account is a type of traditional IRA, account beneficiaries needn’t have gross income to receive or make contributions to their account, and contributions don’t count toward the contribution limits on IRAs that aren’t Trump accounts.

During the growth period, the account must be invested in a mutual fund or exchange-traded fund that:

• Tracks the returns of the S&P 500 index or another index consisting of equity investments in primarily US companies for which regulated futures contracts are traded
• Doesn’t use leverage
• Charges annual fees and expenses of 10 basis points or less
• Meets other criteria the Treasury Secretary deems appropriate

Notice 2025-68 says the trustee is responsible for offering only eligible investments as investment options for the account, including monitoring the investments on an ongoing basis to ensure they remain eligible.

The law generally prohibits distributions during the growth period, with exceptions for qualified rollover contributions to another Trump account or an ABLE account, distributions of excess contributions, or distributions upon the account beneficiary’s death. After the growth period, distributions are generally subject to the rules for traditional IRAs. Distributed amounts are taxable as ordinary income to the extent they’re attributable to pilot program contributions, qualified general contributions, employer contributions, and earnings. Individual contributions are considered nontaxable “basis.” The 10% early withdrawal penalty for distributions prior to age 59½ also applies unless the account beneficiary qualifies for one of the exceptions under the ordinary rules for IRA distributions, which include distributions for qualified higher education expenses, qualified birth or adoption expenses, and qualified first-time homebuyers.

After the growth period, the account beneficiary can transfer their account to another IRA or to an employer-sponsored plan that’s an “eligible retirement plan” under the IRC’s rollover rules. However, a footnote to Notice 2025-68 explains that a Trump account with any nontaxable basis can’t be transferred to a qualified plan, 403(b) plan, or governmental 457(b) plan. Notice 2025-68 doesn’t address whether these plans are required to accept transfers from Trump accounts or how plan administrators can ensure the transfer doesn’t include nontaxable basis.

The program also must meet a series of conditions similar to the requirements for DCAPs under IRC Section 129(d).

• Nondiscriminatory eligibility classification. The program must benefit employees who qualify under a classification Treasury finds not discriminatory in favor of highly compensated employees (HCEs), as defined in IRC Section 414(q), or their dependents. When applying these rules for DCAPs, sponsors may exclude from consideration employees who haven’t attained age 21 and completed one year of service, as well as certain collectively bargained employees. However, new IRC Section 128 doesn’t expressly incorporate that exclusion for testing Trump account contribution programs. Notice 2025-68 doesn’t provide any guidance on whether the same exclusions can be applied to these programs.
• Employee notification requirements. The statute also incorporates DCAP provisions requiring employers to provide eligible employees with reasonable notification of the availability and terms of the program and furnish each employee, on or before January 31, a written statement showing the amounts paid or expenses incurred by the employer in providing benefits to the employee during the previous calendar year.
• Average benefits test. These programs are also subject to the average benefits test applicable to DCAPs. This test requires the average benefits provided to nonhighly compensated employees to be at least 55% of the average benefits provided to HCEs.