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IRS Form 5329 · Excise Tax · June 2026

Form 5329 Missed RMD: How to Report the IRS Additional Tax and When a Waiver May Apply

By The Retirement Index Editorial Team

Published Last reviewed Fact-checkedCites IRS, SEC, FINRA, CFPB

By The Retirement Index Editorial Team · · Next review: · Affiliate disclosure

Sources used. IRS Publication 590-B (2025). IRS Instructions for Form 5329 (2025). IRS RMD FAQs. IRS Notice 2022-53. IRS Notice 2024-35. All accessed 2026-06-13.

Quick answer

If you missed a required minimum distribution (RMD) from an IRA or retirement plan, Form 5329 is the IRS form you often use to report the additional tax tied to a missed RMD and, if eligible, request a waiver. The default excise tax is generally 25% of the amount not distributed as required, but may be reduced to 10% if corrected within the IRS correction window.

Bottom line

For most people, a missed RMD is not solved by just taking the distribution later. You still may need to report the shortfall on Form 5329 and explain why the miss happened. IRS instructions say the tax may be waived part or all of the way if you can show the failure was due to reasonable error and you are taking reasonable steps to remedy it. The exact result depends on the tax year, the account type, the size of the miss, and whether a year-specific relief rule applies.

What "missed RMD" means

An RMD is the minimum amount the IRS requires you to take from certain retirement accounts each year. A missed RMD usually means you took less than the required amount by the deadline.

That is different from:

  • An early distribution
  • An excess contribution
  • A rollover mistake

Form 5329 covers several retirement-tax issues, so it helps to confirm you are dealing with an actual RMD shortfall before you file anything.

What Form 5329 does for a missed RMD

Form 5329 is commonly used to report the additional tax tied to a missed RMD. It is also the form used when you want to request a waiver of some or all of that tax.

The IRS instructions say the waiver is not automatic. You must show:

  1. The failure was due to reasonable error
  2. You are taking reasonable steps to remedy the shortfall

How to tell if you actually missed an RMD

A missed RMD starts with a simple comparison: required amount vs. actual amount distributed. The required amount is generally based on the prior December 31 balance divided by the applicable distribution period or life expectancy factor from the IRS tables in Publication 590-B.

Gather these items:

  • Your account balance as of December 31 of the prior year
  • The IRS distribution factor used to compute the RMD
  • The amount actually distributed
  • The date each distribution was made
  • Whether more than one IRA or retirement account was involved

Simple reconciliation formula: Missed amount = required RMD − amount actually distributed

The penalty rate: 25% baseline, with possible reduction

IRS guidance states the missed-RMD excise tax can be 25% of the amount not distributed as required. The IRS also states 10% may apply if the amount is withdrawn within 2 years, according to its RMD topic page.

In reality, you may be looking at:

  • The default 25% excise tax
  • A reduced 10% rate in certain timing situations
  • A waiver/relief path if IRS conditions are met

Do not assume the same outcome applies to every year or every account.

How the waiver request works

Form 5329 allows the IRS to waive part or all of the additional tax if the miss happened because of reasonable error and you are taking reasonable steps to remedy the shortfall. That is a facts-and-circumstances test, not an automatic pass.

What "reasonable error" usually means

The IRS instructions do not treat every mistake the same. A waiver request should explain, in plain language, what went wrong and why it happened despite ordinary care.

Examples of the kind of factual explanation you may need:

  • A custodian processing issue
  • A calculation misunderstanding
  • A timing or system error
  • A missing or delayed distribution instruction

What "reasonable steps to remedy" usually means

Examples:

  • Taking the missed distribution as soon as possible
  • Documenting when you discovered the shortfall
  • Keeping records showing the correction date
  • Explaining the steps taken to prevent a repeat mistake

What to avoid

  • Don't treat the waiver as automatic
  • Don't give a vague story with no dates
  • Don't guess at the RMD math
  • Don't assume the IRS will overlook missing records

What to gather before you complete Form 5329

The strongest Form 5329 submission is built on clean records. Keep a file with:

  • Prior-year-end account statement
  • RMD calculation worksheet
  • Custodian distribution confirmations
  • Dates of any corrective withdrawals
  • Any IRS notices or correspondence
  • A short written explanation of the error and correction

A waiver request is easier to evaluate when the facts are clear. If your numbers, dates, and explanation line up, your filing is easier to review.

Special note for Gold IRA and self-directed IRA owners

A Gold IRA still follows the same IRS RMD rules as other IRAs. The difference is practical: selling assets, moving cash, and processing distributions can take extra time, so missed-RMD risk may be higher if you do not plan ahead.

That does not change the IRS rulebook. It just makes documentation and timing more important.

Operational issues to watch

  • Time needed to liquidate metals
  • Custodian processing time
  • Wire or check delivery timing
  • Whether you requested the distribution early enough to meet the deadline

If your IRA is self-directed, build in extra time well before the RMD deadline.

2024 relief language in Publication 590-B

IRS Publication 590-B (2025) describes a 2024 relief rule for missed required minimum distributions in certain situations. Review the specific conditions in the publication before relying on it.

This kind of relief can affect:

  • Whether the IRS asserts the tax at all
  • Whether Form 5329 should be filed in a particular way
  • How you explain the correction

Because the rules are year-specific, do not rely on memory or old penalty articles. Check the current IRS publication for the exact requirements.

Step-by-step action plan for a missed RMD

Step 1: Confirm the miss

Compare the required amount with the amount actually distributed.

Step 2: Check the tax-year rule

Look at the IRS RMD guidance and Publication 590-B for that year.

Step 3: Correct the shortfall

If you have not yet taken the full RMD, take the remaining amount as soon as practical.

Step 4: Prepare the waiver explanation

If you are asking for relief, explain the error and the remedy clearly and factually.

Step 5: Complete Form 5329

Follow the IRS instructions for the missed-RMD penalty section and waiver request lines, and keep copies of everything you submit.

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Common mistakes that weaken a waiver request

Most missed-RMD problems get worse when people rush, guess, or file without the right records. The IRS is looking for facts, not frustration.

Frequent errors

  • Using the wrong account balance
  • Forgetting one IRA in a group
  • Confusing the RMD year with the withdrawal year
  • Filing without proof of the corrective distribution
  • Writing a vague waiver explanation
  • Assuming the IRS will automatically forgive the miss

Work from documents, not memory. Match every number to a statement, a calculation, or a distribution record.

Form 5329 missed RMD: practical checklist

  • Identify the tax year of the missed RMD
  • Confirm the required amount using IRS methods
  • Confirm the amount actually distributed
  • Calculate the shortfall
  • Check whether the IRS year-specific relief applies
  • Decide whether to request a waiver
  • Assemble statements, confirmations, and dates
  • Complete Form 5329 using the IRS instructions
  • Keep copies of everything you submit

FAQ: Form 5329 missed RMD

Do I always have to file Form 5329 if I missed my RMD?

In many missed-RMD cases, you file Form 5329 to report the additional tax and request a waiver if eligible. However, the IRS instructions also describe specific situations where a separate filing may not be needed depending on how the distribution was reported and how the instructions apply to your case.

Is the penalty for a missed RMD always 25%?

No. IRS guidance describes 25% as the baseline, but it also says 10% may apply if corrected within 2 years, and some years may have specific relief rules such as Notice 2022-53 or Notice 2024-35.

What does 'reasonable error' mean for a waiver request?

It means the failure must be explainable as a real mistake, not a casual choice to skip the RMD. The IRS instructions require a factual explanation tied to the miss — for example, a custodian processing issue, a calculation misunderstanding, or a timing error.

If I already corrected the missed RMD, do I still need Form 5329?

Possibly. Correction does not always eliminate the need to report the issue or request a waiver. The IRS still wants to see that you have addressed both the distribution shortfall and the tax reporting question.

Does the 2024 relief in Publication 590-B apply automatically?

No. Publication 590-B describes a 2024 relief rule in certain situations. You need to verify the specific conditions in the publication before relying on it.