On March 6, 2026, Treasury and the IRS issued proposed regulations for Trump Accounts, which were published in the Federal Register on March 9 – two proposed rulemakings that provide the clearest picture yet of how the program will actually work. If you've already filed Form 4547 or are thinking about it, here's what these new rules mean for your family.
What these regulations cover
The two proposed rules address the foundational mechanics of the program:
REG-117270-25 covers how to open an initial Trump Account, who is authorized to do so, and who serves as the responsible party once the account exists.
REG-117002-25 covers the $1,000 Pilot Program Contribution – the one-time government deposit for children born between 2025 and 2028.
Much of the guidance follows what Treasury previewed in Notice 2025-68 last December. There is some additional detail, but the regulations are notable as much for what they don't address as for what they do.
Who can open an account
The regulations confirm that any child with a Social Security Number who has not turned 18 before the end of the calendar year qualifies for a Trump Account. There are no income limits.
An “authorized individual” must make the election on the child's behalf. If the $1,000 pilot election is being made at the same time as the account election, the person authorized to make the pilot election is automatically the authorized individual.
Otherwise, the regulations establish this priority order:
Legal guardian
Parent
Adult sibling
Grandparent
If multiple people share the same priority level, any one of them may make the election. The authorized individual must represent under penalty of perjury that they are authorized and that no one with higher priority has already made the election.
A critical warning for the $1,000 contribution
If your child was born between 2025 and 2028, the account should only be opened by the child's parent or legal guardian. Here's why: the $1,000 pilot contribution requires the child to be a qualifying child under IRC §152(c) of the person making the election. If a grandparent or adult sibling opens the account first, there may be no way for the parent to later claim the $1,000 government deposit – because the child can only have one funded Trump Account at a time. This is one of the most important practical takeaways from the new rules.
How the $1,000 pilot contribution works
The regulations introduce a new concept called the “pilot program-electing individual” – the person authorized to request the $1,000 government deposit. To qualify, the child must:
Be born between January 1, 2025 and December 31, 2028
Be a U.S. citizen
Have a Social Security Number
Be a qualifying child under IRC §152(c) (or anticipated qualifying child for the election year) of the person making the election
The regulations provide some flexibility here: because qualifying child status can't be determined conclusively until the end of the tax year, the electing individual only needs to anticipate that the child will be their qualifying child. If it turns out the child doesn't meet the technical definition, the election won't be voided solely on that basis.
You have time
The regulations confirm a broad election window. The $1,000 pilot contribution can be elected starting the day a child meets the eligibility criteria, all the way through December 31 of the calendar year the child turns 17. So even if you don't file Form 4547 right away, you have years to claim it.
That said, there is no relief for untimely elections – if you miss the deadline, the IRS will not grant an extension.
Where the $1,000 goes
The pilot contribution can be deposited into either the initial Trump Account held at Treasury, or a rollover Trump Account at a private financial institution. This is a welcome clarification – it means you don't need to keep the account at Treasury just to receive the government deposit.
No automatic enrollment
Although earlier information noted the possibility of auto-enrollment into Trump Accounts, the IRS will not automatically open accounts on behalf of children, citing taxpayer data confidentiality concerns. Every family must opt in by filing Form 4547 or using the electronic application at trumpaccounts.gov.
There is one narrow exception: if an unauthorized person files an election, Treasury may make a corrective election on behalf of the eligible child so the account remains valid.
Who holds the account
All initial Trump Accounts are established with Treasury. The responsible party can later transfer the account to a private financial institution through a qualified rollover contribution. Any person approved by the IRS as a nonbank IRA trustee as of December 31, 2025 is automatically approved to act as a Trump Account trustee. Trustees approved later must request Trump Account approval separately.
The growth period, defined
The regulations formalize the “growth period” – the window during which special Trump Account rules apply:
Begins when the initial Trump Account is established
Ends on December 31 of the calendar year the account beneficiary turns 17
After the growth period ends, the account defaults to standard traditional IRA rules and the beneficiary gains full control.
What the regulations do NOT address
Treasury explicitly reserved entire sections of the regulations for future guidance. These are areas where families will need to wait for answers:
Investment rules: Which specific funds or indexes will qualify, whether there will be a default investment option, and how the 0.10% fee cap will be administered in practice
Contribution mechanics: Exactly how family contributions (up to $5,000/year), employer contributions (up to $2,500/year under Section 128), and government/nonprofit contributions will work operationally
Distribution rules: No additional detail on withdrawal exceptions during the growth period, or what happens after the growth period ends
Reporting requirements: How account holders, trustees, and employers will report activity to the IRS
Rollover mechanics: Very little new information on the process for transferring from the initial Treasury account to a private custodian
Special situations: Treasury specifically requested public comments on how the rules should handle foster children, orphans, wards of the state, and emancipated minors
Employer contribution guidance under new Code Section 128 – including whether employees can make pre-tax Trump Account contributions through a cafeteria plan – is expected later in 2026 but is not part of this rulemaking.
Are these rules final?
No. These are proposed regulations. Treasury is taking public comments – the official comment deadline is May 8, 2026. Final rules are expected before the program officially opens July 4.
What you should do now
If your child was born 2025-2028: File Form 4547 with your 2025 tax return or at trumpaccounts.gov to claim the account and the $1,000 pilot contribution. Make sure the filer is the child's parent or legal guardian.
If your child was born before 2025: You can still open a Trump Account using the same form. Your child won't qualify for the $1,000, but you'll be positioned for family and employer contributions once they open in July.
If you've already filed: No action is needed right now. Treasury will send activation instructions starting in May 2026.
Stay informed: Significant additional guidance is still forthcoming on investments, contributions, distributions, and rollovers. Sign up for updates and we'll let you know when it matters.
The bottom line
These regulations are a meaningful step forward, but they're a foundation – not the full picture. Families now have clear rules for opening accounts and claiming the $1,000, but the operational details around investing, contributing, and eventually accessing the money are still months away. The good news: you have time, and the broad election window means there's no rush to act before you're ready.
Source documents: Federal Register Documents 2026-04533 (REG-117270-25, 91 FR 11194) and 2026-04534 (REG-117002-25, 91 FR 11203), published March 9, 2026.
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