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Seyfarth Synopsis: Since Trump Accounts made their debut as the “New Kid on the IRA Block” in December 2025, Treasury and the IRS have released proposed regulations that add important—but not always simplifying—details to the program.
The proposed regulations, released on March 9, focus heavily on pilot contribution eligibility and enrollment, adding new protections against multiple accounts being opened for the same child. Unfortunately, none of the newly proposed regulations speak to the mechanics of employer contributions to Trump Accounts.
Confirmed Designs
The proposed regulations specify that the $1,000 federal pilot contribution applies only to children born 2025–2028, who are U.S. citizens with a Social Security Number (SSN) and have no prior pilot program election on file.
Authorized individuals can elect to open a Trump Account for a child at any time from SSN issuance through the end of the year in which the child turns 17. The IRS reaffirmed the use of Form 4547 to establish a Trump Account and request the $1,000 pilot program contribution.
Trump Account contributions cannot begin until July 4, 2026. An annual $5,000 total contribution cap will apply (including up to $2,500 from employers). Importantly, the proposed regulations confirm that any pilot program contributions do not count towards the annual $5,000 limit. Investments remain limited to index funds primarily composed of U.S. equity investments.
As a reminder, Trump Account funds generally remain locked until the year the child turns 18 and will typically follow traditional IRA rules after the child turns 18 (at which point the funds can be used for a variety of qualifying purposes, including education expenses, job training, down payment on a first home, capital to start a small business, and retirement).
Administrative Questions
On April 6, 2026, Treasury announced that the Bank of New York Mellon Corporation (“BNY”) will manage initial Trump Accounts and develop an associated app. Robinhood will serve as the brokerage and initial trustee of Trump Accounts.
Otherwise, many open questions remain with respect to the establishment and administration of Trump Accounts. For employers specifically, unanswered questions include applicable ERISA exemptions, plan document requirements and coordination with Section 125 cafeteria plans—all issues Treasury says it will address at a later date.
Takeaway
The Trump administration remains committed to the Trump Account program and eligible families will have the option to open a Trump Account when submitting their 2025 federal tax return. However, many open questions remain. We expect additional guidance later this year.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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