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IRS Form 5329 · Excise Tax · June 2026

Inherited IRA RMD Penalty Waiver: What's Actually Possible, and When

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 Notice 2022-53. IRS Notice 2024-35. IRS RMD FAQs. IRS required minimum distributions for IRA beneficiaries. All accessed 2026-06-13.

Quick answer

There is no single automatic waiver that applies to every missed inherited traditional IRA RMD. Relief may come from a limited IRS notice for specific years or from a case-by-case waiver request showing reasonable error and reasonable remediation steps. The penalty is generally 25% of the missed amount but can drop to 10% if corrected within the IRS correction window.

What "waiver" really means

An inherited IRA RMD "waiver" can mean two different things. It may refer to notice-based relief the IRS gives for certain missed RMD years, or it may mean a request-based waiver where you ask the IRS to forgive the excise tax because the mistake was reasonable and you corrected it.

The two relief paths

Path 1: Notice-based relief. This is limited, year-specific relief. It applies only when the IRS says it will not assert the excise tax for certain missed RMDs and only if you fit the notice's rules.

Path 2: Waiver by request. If notice relief does not apply, the IRS says the penalty may be waived if you can show reasonable error and that you are taking reasonable steps to fix the shortfall. You may need to file Form 5329 and attach a letter of explanation.

What the IRS means by an excise tax

For missed inherited traditional IRA RMDs, the IRS says you may have to pay an excise tax on the amount not distributed as required. In the IRS FAQs, that penalty is commonly framed as 25% of the amount not taken by the deadline, but the exposure and any relief depend on the year and your facts.

Three separate questions to keep straight

  1. Did you actually miss an RMD?
  2. Does a limited IRS notice cover your year and situation?
  3. If not, can you request waiver relief?

Those are not the same thing.

Why inherited IRA RMD rules matter before you talk about penalties

Whether there was a real miss depends on the inherited IRA rules themselves. The IRS says the required distribution rules vary based on:

  • Whether you are a surviving spouse or non-spouse beneficiary
  • Whether the original IRA owner died before or after the required beginning date
  • The beneficiary category and distribution schedule that applies

If the wrong schedule was used, the "missed RMD" may really be a calculation or classification problem.

Common ways people end up with a false "miss"

  • The beneficiary was classified incorrectly
  • The custodian used the wrong schedule
  • The person assumed the 10-year rule meant "no annual withdrawals" in every case
  • The account inherited as a spouse account when it should have been treated differently
  • The distribution was taken, but in the wrong year or for the wrong amount

Notice-based relief: the limited "automatic" relief people search for

Some people search for "automatic" penalty relief because the IRS has issued limited-year notices that say it will not assert the excise tax for certain missed RMDs if the conditions are met. That relief exists, but it is not blanket relief for all inherited traditional IRAs and all years.

Notice 2022-53: relief for certain 2021 and 2022 missed RMDs

Notice 2022-53 is one of the most searched relief notices. It applies to certain missed RMDs in 2021 and 2022 and uses the concept of a "specified RMD."

The practical takeaway:

  • If your missed RMD year is not 2021 or 2022, this notice likely does not solve your problem
  • If your year is 2021 or 2022, you still need to check whether your missed amount qualifies as a specified RMD under the notice's definitions

2024 relief referenced in Publication 590-B

The IRS's Publication 590-B (2025 edition) references Notice 2024-35 for certain missed RMD relief in 2024. This is not a permanent inherited IRA RMD penalty waiver for every case. Publication 590-B points to Notice 2024-35 for limited, condition-based relief in 2024; readers must check the notice's eligibility requirements.

The main lesson from notice relief

Notice-based relief is best thought of as:

  • Limited
  • Year-specific
  • Fact-specific

If your situation fits, you may be in better shape. If not, move to the request-based waiver path.

If notice relief does not apply: the waiver request path

If your missed inherited traditional IRA RMD is outside a notice window, the IRS still may waive the excise tax if you qualify under its reasonable error standard.

What the IRS asks for

The IRS says penalty relief may be available if:

  • The shortfall was due to reasonable error
  • You are taking reasonable steps to fix it
  • You file Form 5329
  • You attach a letter of explanation

What to include in your explanation

A strong explanation usually includes:

  • Your name and beneficiary status
  • The original IRA owner's date of death
  • The missed RMD year
  • How the RMD was calculated
  • Why the mistake happened
  • When you discovered it
  • When and how you corrected it

What "reasonable steps" means in practice

Reasonable steps usually means you did not ignore the problem once you found it. Good records help:

  • Take the corrective distribution as soon as practical
  • Keep the account statements
  • Keep a timeline of events
  • Keep any custodian emails or letters
  • Keep the calculation worksheet you used

The numbers that matter: 25%, and why correction timing still matters

The IRS FAQs say missed RMDs may be subject to an excise tax of 25%. That is the number to keep in mind when a distribution is short or missed, but the actual outcome depends on the facts and whether any relief applies.

Taking the money later can help correct the shortfall, but it does not automatically erase the tax issue. You still need to know:

  • Whether notice relief applies
  • Whether you need to request waiver relief
  • Whether Form 5329 should be filed
  • Whether your explanation is strong enough

Penalty relief, including waivers based on reasonable error, is not guaranteed.

Step-by-step: what to do if you missed an inherited IRA RMD

Step 1: Confirm the facts

Gather:

  • The account title and beneficiary type
  • The date the IRA owner died
  • Whether the owner died before or after the required beginning date
  • The year the RMD was due
  • The custodian's calculation, if any
  • Statements showing what was actually withdrawn

Step 2: Check whether a notice-based relief year applies

Ask:

  • Was the missed year 2021 or 2022? If yes, review Notice 2022-53 and whether your missed amount is a specified RMD under the notice.
  • Was the missed year 2024? Review the relief referenced in Publication 590-B and Notice 2024-35 and its eligibility requirements.

If you do not fit one of those windows, move on.

Step 3: If no notice relief fits, prepare the waiver packet

Your packet should include:

  • Form 5329
  • A letter of explanation
  • Copies of supporting records
  • Proof of the corrective distribution

Step 4: Write the explanation clearly

Keep it plain and factual. Cover: what happened, why the error was reasonable, when you found it, and what steps you took to fix it. Do not overstate your case.

Step 5: Keep a paper trail

Save the original statement, the correction confirmation, the explanation letter, any custodian correspondence, and any calculation worksheets.

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A simple decision map for readers

QuestionIf yesIf no
Was the missed year 2021 or 2022?Check Notice 2022-53 and whether your missed amount is a specified RMD under the noticeMove to waiver request
Was the missed year 2024?Check the relief referenced in Pub. 590-B / Notice 2024-35 and its eligibility requirementsMove to waiver request
Can you show reasonable error and reasonable steps?Prepare Form 5329 + letterRe-check facts and records
Was the inherited IRA schedule correct?Focus on penalty reliefReassess whether the miss happened at all

FAQ: inherited IRA RMD penalty waiver

Is there an automatic inherited IRA RMD penalty waiver?

No. There is no single automatic waiver that applies to every missed inherited traditional IRA RMD. Relief may come from a limited IRS notice for specific years (such as Notice 2022-53 for 2021–2022 misses) or from a case-by-case waiver request showing reasonable error and remediation steps.

What does the IRS require to request a waiver?

The IRS says penalty relief may be available if the shortfall was due to reasonable error, you are taking reasonable steps to fix it, you file Form 5329, and you attach a letter of explanation. That letter is how you explain what happened, why it happened, and how you corrected it.

What is the missed inherited IRA RMD penalty rate?

The IRS FAQ says missed RMDs may be subject to an excise tax of 25% of the amount not taken by the deadline. This can be reduced to 10% if corrected within the IRS correction window, subject to IRS rules.

Does Notice 2022-53 cover all missed inherited IRA RMDs?

No. Notice 2022-53 applies only to certain missed RMDs in 2021 and 2022, and only if your missed amount qualifies as a 'specified RMD' under the notice's definitions. If your missed year is not 2021 or 2022, this notice likely does not solve your problem.

What does Form 5329 do for a missed inherited IRA RMD?

Form 5329 is the IRS form used to report the additional tax tied to a missed RMD and, if eligible, request a waiver. Filing it with a clear, factual letter of explanation is how you formally make the waiver request to the IRS.