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Trump Accounts: A Plain-Language Guide for Employers and the Questions Your Employees Will Ask

Key Takeaways

  • A Trump Account is a traditional IRA for a child, not a college fund. Money is invested in U.S. stock index funds, locked until 18, and taxed as ordinary income at withdrawal.
  • The $1,000 federal contribution is real but not automatic. It requires an election by a parent or guardian and applies only to eligible children born 2025 through 2028.
  • Employee questions are already reaching HR teams. With more than 6 million children enrolled, per the Treasury Department, employees are asking about eligibility, the $1,000 federal contribution, and how the accounts work.
  • Trump Accounts become traditional IRAs at adulthood. Starting the year the child turns 18, the account generally follows traditional IRA rules for contributions, withdrawals, and taxation.

What Is a Trump Account?

A Trump Account is a specialized traditional IRA established for a child, created by the One Big Beautiful Bill Act of 2025 under new Code Section 530A. A parent or guardian opens it, the child owns it, and the money is invested and left to compound until adulthood. The basics:

  • Eligibility. A U.S. citizen child under 18 with a valid Social Security number. One account per child, no family income limits, and no earned income requirement.
  • The federal seed. A one-time $1,000 government contribution for eligible children born between 2025 and 2028. It requires an election by a parent or guardian. It is not automatic.
  • Contributions. Up to $5,000 per year per child from family, friends, and employers combined, after-tax, indexed for inflation after 2027. The federal seed and qualified charitable or government contributions sit outside that cap.
  • Investments. Restricted to low-cost funds tracking the S&P 500 or another broad U.S. stock index, with fund fees capped at 0.10%.
  • Access. Locked until January 1 of the year the child turns 18. After that, ordinary traditional IRA rules apply, including ordinary income tax on withdrawals.

Where Did the Idea Come From?

Policy thinkers have floated child savings accounts for decades under the label of baby bonds. The United Kingdom ran a national version, the Child Trust Fund, from 2002 to 2011, seeding an account for every newborn. 

In the United States, proposals surfaced repeatedly in Congress, from the bipartisan ASPIRE Act in the mid-2000s to Senator Cory Booker's American Opportunity Accounts. 

The arguments were consistent across parties: starting at birth gives compounding its longest possible runway, and universal accounts pull families into the financial system who might otherwise never open an investment account.

The 2025 version began in the House as Money Accounts for Growth and Advancement before being renamed Trump Accounts in the final bill. The One Big Beautiful Bill Act was signed on July 4, 2025, the IRS issued initial guidance that fall, and accounts opened for enrollment and funding exactly one year after signing. 

The underlying design is an idea that has circulated in policy circles for a generation.

What Should Employers Expect From Here?

Three things, roughly in order:

  • Employee awareness will keep climbing. The federal seed gives millions of families a reason to enroll, and enrollment runs through the IRS and trumpaccounts.gov, which means ordinary employees are interacting with it directly. Questions will land on HR whether or not your company does anything.
  • Guidance will keep arriving. The statute is in place, but regulations on employer programs, nondiscrimination testing, payroll tax treatment, and coordination across employers are still being finalized. Expect the details to move through 2026 and 2027.
  • Employer contributions will spread. Large employers including Bank of America, Charles Schwab, JPMorgan Chase, SoFi, and Visa have announced contribution programs. As programs become visible, employees will start asking whether your company offers one. That is a policy decision, and it deserves a deliberate answer either way.

The Questions Your Employees Will Ask

These are the questions showing up first, with short factual answers.

Is my child eligible?

A U.S. citizen child under 18 with a valid Social Security number can have an account. The $1,000 federal contribution is limited to eligible children born between January 1, 2025 and December 31, 2028.

Is the $1,000 automatic?

No. A parent or guardian must file an election, either with a tax return on IRS Form 4547 or online at trumpaccounts.gov.

Is this a college fund?

Not in the 529 sense. It is a traditional IRA for the child. Withdrawals after 18 are taxed as ordinary income, and early withdrawals can carry a penalty, with exceptions that include higher education.

We already have a 529. Do we need this too?

They do different jobs, and many families will use both. A 529 offers tax-free withdrawals for qualified education and a broader investment menu. A Trump Account offers the federal seed and a long-horizon account that becomes an IRA. Neither replaces the other.

Does the company contribute?

Employers may contribute up to $2,500 per employee per year through a written program, excluded from the employee's taxable income. Offering a program is entirely voluntary, and each company decides for itself.

Can I contribute from my paycheck?

Possibly, through a Section 125 cafeteria plan for a dependent's account, but the mechanics are still being clarified in guidance. Employees should not expect a payroll deduction option immediately.

These answers describe a public program in general terms. Decisions about enrolling or contributing are personal, and employees weighing them are best served by their own tax or financial advisor.

The Retirement Plan Connection

Underneath the headlines, a Trump Account is a retirement account. Every child enrolled this year will enter the workforce already holding a traditional IRA, some with two decades of compounding behind it. That is genuinely good news, and it is why these questions land with whoever looks after your retirement plan.

First, what it is not. A Trump Account program is not part of your 401(k) or 403(b). It does not touch plan assets or your recordkeeper, and under current DOL guidance it generally is not an ERISA plan, because the account belongs to the employee's child.

If your company chose to participate, the shape is simple:

  • Adopt a short written plan document and tell employees the program exists.
  • An employee opens a Trump Account for their child.
  • You contribute up to $2,500 per year through payroll, reported on the W-2.
  • The contribution is generally deductible for the company and tax-free to the employee.
  • Your role ends at funding. No investment picks, no fiduciary duties. The account belongs to the family.

Some employers will offer this, and many will reasonably wait while the rules are finalized. Either answer is fine, decided thoughtfully. If you would like to talk through what Trump Accounts could mean for your employees and your benefits, please reach out us. We would be glad to hear from you.

Sources

  • Internal Revenue Code Sections 530A and 128; One Big Beautiful Bill Act of 2025 (Pub. L. 119-21)
  • IRS Notice 2025-68; IRS Form 4547 and trumpaccounts.gov
  • U.S. Department of Labor, Technical Release 2026-02 (June 17, 2026)
  • Congressional Research Service, Trump Accounts: Overview and Policy Considerations (R48910)

Disclosures

Educational purpose only. Provided by First Hill Trust Company for general informational and educational purposes only. It is not legal, tax, accounting, investment, or fiduciary advice, does not constitute a recommendation regarding any plan, investment, strategy, or course of action, and does not consider any recipient’s specific circumstances. Consult your own qualified advisors before acting.

No offer, agreement, or commitment. Nothing in this material constitutes an offer, solicitation, agreement, or commitment to provide any particular service or to assume any particular responsibility. Descriptions of what a trustee, administrator, adviser, committee, employer, or other party “may” or “can” do are illustrative of how such arrangements commonly work and do not describe the terms of any specific engagement. The actual services provided, the allocation of responsibilities, the scope of any delegation, and the duties of any party are governed solely by the applicable plan documents, trust agreement, advisory agreement, and written service agreements. In the event of any inconsistency, those documents control.

Services and regulatory status. First Hill Trust Company and its affiliates offer retirement plan services, recordkeeping and administrative services, trust and fiduciary services, investment advisory services, and group benefits services, in each case subject to applicable regulatory requirements and the terms of the relevant agreements. Not all services are offered to all clients, in all states, or in all circumstances. Investment advisory services are offered through an affiliated investment adviser; a copy of its Form ADV Part 2A is available upon request. Insurance and group benefits products are offered through appropriately licensed entities. The availability and scope of any service depend on eligibility and the applicable agreements.

Fiduciary status under ERISA. Fiduciary status under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), is determined based on the functions performed and the authority exercised, not on titles or labels. Whether any particular party is acting as a fiduciary, and the scope of any related duties or potential liability, depends on the facts and circumstances specific to the plan and the relationship. Engaging a trustee, adviser, or other service provider does not eliminate a plan sponsor’s or committee’s own fiduciary responsibilities, including the duties to prudently select and monitor any party to whom responsibilities are delegated.

Affiliated entities and conflicts of interest. First Hill Trust Company is affiliated with other entities, including an affiliated investment adviser and entities providing administrative, trust, or other services. These relationships may create conflicts of interest, including where an affiliate is engaged or compensated in connection with a plan. Such conflicts and compensation are described in the applicable service agreements and the affiliated adviser’s Form ADV Part 2A; fiduciaries should consider them when evaluating any engagement.

References to ERISA, the Internal Revenue Code, SECURE 2.0, Washington Saves, or other federal or state laws, regulations, or government programs are general summaries only and should not be interpreted as legal guidance or a complete statement of the law. Laws, regulations, agency guidance, and program requirements are subject to change and interpretation. Examples and illustrations are simplified for explanatory purposes and may not reflect every circumstance or apply to every employer or retirement plan.

Unless otherwise noted, figures, contribution limits, tax credits, and other numerical examples are current as of 2026 and are subject to change. IRS contribution limits and catch-up amounts are adjusted periodically for inflation. Eligibility for SECURE 2.0 tax credits depends on individual facts and circumstances. Certain Washington Saves program provisions, including default contribution rates, investment options, and implementation details, remain subject to final program rules and may change before implementation.

Statutory and regulatory references. References to ERISA, the Internal Revenue Code, and related statutory or regulatory provisions are general summaries only. They are not a substitute for review of the actual statutory text, regulations, or guidance from the Department of Labor, Internal Revenue Service, or other relevant authorities, and they do not address how those provisions may apply to any particular plan, sponsor, fiduciary, or individual. Laws, regulations, and guidance are subject to change and to interpretation by the relevant agencies and courts. Examples, categories, and situations described are simplified for illustration and may not reflect the requirements or circumstances of any particular plan or person.

No guarantee of results; investment risk. References to governance, fiduciary practices, risk reduction, or outcomes describe common industry approaches and potential benefits, not promises or guarantees of any result, of compliance, or of protection from liability, loss, or claims. All investing involves risk, including possible loss of principal; diversification does not ensure a profit or protect against loss. Past performance does not guarantee future results.

For more information, contact First Hill Trust Company at (206) 625-1800.

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