Treasury Issues Employer-Focused Guidance on Trump Accounts (Section 530A Accounts)

Treasury Issues Employer-Focused Guidance on Trump Accounts (Section 530A Accounts)
August 14, 2026 9 mins

Treasury Issues Employer-Focused Guidance on Trump Accounts (Section 530A Accounts)

Trump Accounts: Key Employer Insights for 530A Plans

What employers need to know about 530A (“Trump”) accounts: how they work, employer opportunities and open questions

Key Takeaways
  1. New Treasury guidance provides implementation clarity. Proposed regulations issued on August 11, 2026 outline employer responsibilities for plan design, administration, reporting, compliance and employee contribution elections.
  2. Employers can play a central role in supporting Trump Accounts. Organizations can contribute directly to employees' children's accounts, offer pre-tax payroll contributions through a Section 125 plan and provide education to help employees take advantage of this new savings opportunity.
  3. Nondiscrimination requirements remain a critical consideration. Employer-funded Trump Account programs must meet rules similar to dependent care assistance plans, with new guidance clarifying testing requirements, safe harbors and correction methods to help employers maintain compliance.

This article was updated on August 11, 2026.

What do Employers Need to Know About Section 530A (Trump) Accounts?

  • Section 530A accounts, commonly known as Trump accounts, are childhood savings vehicles intended to give children a head start for a secure financial future. These accounts went live on July 4, 2026.
  • Employers can directly fund employees’ or their dependents’ accounts or provide a pre-tax saving opportunity for employees to contribute to these accounts through salary reductions via a Section 125 (“cafeteria”) plan.
  • On August 11, 2026, Treasury issued proposed regulations regarding Trump account employer contribution plan management and compliance requirements.
  • These proposed regulations also provide helpful guidance regarding nondiscrimination testing for dependent care spending accounts, as well as Trump accounts.
  • Employer plans will be important to the success of these childhood savings accounts as they can provide contributions, tax benefits, and valuable financial education.

What are Section 530A (Trump Accounts)?

Internal Revenue Code Section 530A accounts, commonly known as Trump accounts, are childhood savings vehicles intended to give children a head start for a secure financial future. Beginning on July 4, 2026, contributions to these accounts can be made by individuals, employers, government entities, and charities, but families must set up a child’s account first.

Section 530A accounts are generally subject to the rules for Individual Retirement Accounts (IRAs), except during their growth period which begins at account initiation and ends on December 31st of the year the child turns age 17. During the growth period, withdrawals from the account are generally prohibited and eligible investments are limited to mutual funds and ETFs that track indices of primarily U.S. companies. After the growth period, IRA rules will take effect, including the 10% additional tax on early distributions.

There are many opportunities to fund these savings vehicles as parents, grandparents, extended family and friends can contribute to a child’s account. Contributions are limited to $5,000 per child in 2026, of which an employer can contribute up to $2,500 per employee through direct funding and/or the employee’s pre-tax salary reductions under a cafeteria plan. Contributions funded by a governmental entity or a charity are not included in the annual dollar limit. A compelling component of the initial roll-out is the federal government’s pilot program that provides a one-time $1,000 contribution available to every child born from January 1, 2025 through December 31, 2028. Several philanthropists have also pledged contributions to millions of children, taking advantage of the framework established to enable such contributions.

How Employers Can Support Trump Accounts

Under Section 128, employers can help fund Section 530A accounts through direct contributions, by facilitating employee pre-tax salary reductions through a cafeteria plan, or both. As of the date of publication, more than 60 employers have already announced support, with most planning to match the $1,000 pilot program contribution for the children of their employees. Many employers are also evaluating the opportunity to offer salary reduction contributions through a cafeteria plan. Combined with DOL guidance issued in June clarifying that employer facilitation of Trump accounts generally does not create an ERISA-covered benefit plan, Treasury’s proposed regulations issued in August will enable employers to move forward with implementation.

Even if an employer isn’t ready to add 530A accounts to their total rewards program, they can play a meaningful role by serving as a trusted source of information for employees. Employers can explain how the accounts work and provide their employees with education on how the accounts can support their children’s financial future. Employer communications through various channels can influence whether and how employees choose to use Trump accounts.

While the federal pilot contribution is currently available only for children born in 2025 through 2028, Section 530A accounts are intended to be an ongoing savings vehicle and have attracted bipartisan interest. Employers can help by providing clear, factual education on account setup, contribution options, and future implementation guidance, while avoiding individualized tax, investment, or legal advice.

New Treasury Guidance for Employer Contributions

Treasury released proposed regulations on August 11, 2026 to support employers that provide funding or access to pre-tax salary reductions for employees’ dependents’ Trump accounts. Treasury adopted many of the suggestions that Aon proposed on its clients’ behalf. Key provisions of the proposed Treasury regulations include:

  • Plan Establishment and Design
    • Employers are precluded from limiting contributions to Trump accounts held by particular trustee(s).
    • The annual tax-favored employer contribution limit is $2,500 per individual, regardless of the number of employers or eligible dependents. The individual will be responsible for managing this limit if they have more than one employer. Amounts in excess of the limit will be taxable wages (and not be refunded to their employer).
    • Employers have no obligation to monitor the annual $5,000 limit per dependent. Excess contributions will be first attributable to other sources of contributions before being attributable to contributions from the employer plan.
    • A written plan document must be established and followed that includes information regarding employee eligibility, any contribution amounts or salary reduction availability, procedures for designating the account to receive contributions, procedures for correcting administrative failures, the plan year, and other reporting and compliance operations.
    • Eligible employees must be notified of the plan.
  • Employee Elections & Contributions
    • Employees can elect to make, change or revoke an election for salary reduction contributions at any time during the plan year. Employers must allow these contribution changes to be made at least once a month.
    • Employers generally may rely on employee self-certification regarding dependent eligibility but must confirm that the account is a valid Trump account.
  • Administration, Reporting & Compliance
    • Employees must receive a statement of prior year contributions by January 31st of the following year. This may be satisfied through Form W-2 reporting.
    • Employers must advise the trustee that the contribution is a Section 128 contribution at the time of the contribution, and notify the trustee if a contribution is later determined to not be a Section 128 contribution.

Nondiscrimination Testing

Employer contributions (including employee pre-tax salary reductions) to Trump accounts must satisfy nondiscrimination rules that are similar to the nondiscrimination rules for dependent care assistance programs (DCAP), prohibiting these programs from discriminating in favor of highly-compensated individuals. These proposed regulations provide guidance on applying the nondiscrimination testing requirements for both Section 128 Trump account contributions and DCAPs. Specifically, the proposed regulations address the following.

  • Clarifies that contributions and benefits are not discriminatory if the program does not provide more favorable terms for highly-compensated individuals than for other employees. The proposed regulations further clarify that this nondiscrimination requirement is satisfied if the program is designed to provide contributions and benefits on the same terms for all eligible employees, even if eligible employees make different elections or have different utilization of the contributions and benefits.
  • Highlights that the program must benefit employees who qualify under a classification established by the employer that is not discriminatory. To meet this requirement, the classification must be reasonable and established under objective business criteria, as determined by either a facts and circumstances test, or a numerical safe harbor.
  • Clarifies rules for determining whether the average benefits provided to non highly-compensated individuals under the program are at least 55 percent of the average benefits provided to highly-compensated employees, in order to meet these nondiscrimination requirements.
  • Provides rules identifying which employees are excluded for purposes of applying the nondiscrimination requirements.
  • For Trump accounts, proposes a safe harbor with respect to employer matching contributions to the government pilot program contributions.
  • Includes rules addressing the failure of employers to satisfy the nondiscrimination requirements and remedial actions.

These rules provide employers with greater clarity regarding administration, compliance, and nondiscrimination testing for Trump account contribution programs while offering flexibility to correct certain failures without broadly affecting employee tax treatment.

Several important operational and implementation questions remain unanswered, including aspects of account setup, trustee coordination, reporting, and other administrative requirements. Additional operational guidance will be needed before many employers can fully evaluate implementation options.

Key Employer Actions to Consider

  • Assess how Trump accounts fit within your organization’s total rewards strategy
  • Communicate the benefits of establishing Trump accounts to employees
  • Model cost, payroll, administrative and nondiscrimination testing implications
  • Design the program, including eligibility and employer contribution approach
  • Establish the plan document
  • Communicate to employees
  • Implement the program and monitor future Treasury and DOL guidance

Contact Us

Grace Lattyak
Partner, Wealth Solutions
grace.lattyak@aon.com

Melissa Elbert
Partner, Wealth Solutions
melissa.elbert@aon.com

Kerri Willis
Senior Vice President, Compliance and Policy
Health Solutions
kerri.willis@aon.com

Daniel Serota
Vice President, Government and Public Affairs
dan.serota@aon.com

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This document is not intended to address any specific situation or to provide legal, regulatory, financial, or other advice. While care has been taken in the production of this document, Aon does not warrant, represent or guarantee the accuracy, adequacy, completeness or fitness for any purpose of the document or any part of it and can accept no liability for any loss incurred in any way by any person who may rely on it. Any recipient shall be responsible for the use to which it puts this document. This document has been compiled using information available to us up to its date of publication and is subject to any qualifications made in the document.

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