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Kit document

Payroll / contribution workflow checklist

⚠️ Educational only

Confirm reporting with your payroll provider and CPA — IRS reporting guidance may still evolve. This checklist reflects proposed regulations (REG-101355-26) published August 11, 2026, which are not yet final. See proposed employer rules explainer for full context.

Pre-launch setup

  1. Establish written plan document — proposed regs require a separate written plan spelling out eligibility, contribution amounts, notices, and procedures
  2. Set up trustee verification process — cannot rely on employee certification alone; must verify Trump Account through trustee, payroll processor, or service provider
  3. Configure contribution identification — ensure payroll system can identify each Section 128 contribution to the account trustee when transmitted
  4. Document GL / benefit code with finance team for proper accounting
  5. Set annual cap controls: ≤ $2,500 per employee (not per child) and track against child's remaining $5,000 room
  6. Draft employee communications — proposed regs require "reasonable notification" to eligible employees about program availability and terms

Employee enrollment

  1. Collect employee attestation: eligible child age, dependent status, and Trump Account established
  2. Verify Trump Account with trustee or service provider (self-certification for age/dependent OK; account itself must be verified)
  3. Capture account identifiers needed for contribution routing (per trustee requirements)
  4. Confirm contribution allocation if employee has multiple eligible children (remember: $2,500 limit is per employee total, not per child)

Contribution processing

  1. Choose contribution cadence: lump sum, quarterly, or payroll-synced
  2. Identify each Section 128 contribution to account trustee when transmitting (proposed reg requirement)
  3. Track year-to-date totals per employee (cap at $2,500) and per child account ($5,000 total from all sources)
  4. Monitor for disqualifying events (e.g., child turns 18, account closed, employee terminates)

Error correction

  1. Review contribution eligibility quarterly or after significant events
  2. If contribution doesn't qualify as Section 128: send corrective notice to trustee within 21 calendar days (proposed reg requirement)
  3. Document correction for tax reporting and employee communication
  4. Coordinate with payroll vendor on W-2 adjustment if contribution becomes taxable

Year-end & ongoing

  1. Reconcile annual totals by employee and by child account
  2. Prepare year-end reporting (format TBD by IRS; coordinate with payroll provider)
  3. Test pilot group before broader rollout if implementing for first time
  4. Publish employee FAQ + support contact for questions
  5. Monitor for final regulations — comment deadline Sept 25, 2026; hearing Oct 15, 2026

✅ Vendor coordination checklist

Questions to ask your payroll provider or benefits administrator:

  • ✓ Can you verify Trump Accounts with trustees or do we need a separate integration?
  • ✓ Does your system identify Section 128 contributions when transmitting to trustees?
  • ✓ How do you track the $2,500 per-employee cap across multiple children?
  • ✓ What's your process for sending corrective notices within 21 days?
  • ✓ How will you handle W-2 reporting if contributions become taxable?

Based on IRC Section 128, IRS Notice 2025-68, and proposed regulations REG-101355-26 (Federal Register, Aug 11, 2026). Proposed rules are not final — build flexibility for adjustments after comment period and public hearing.

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