Interest in so-called "Trump Accounts" is growing based on all the news about the matching programs that have been announced by Michael Dell, founder of Dell, Inc., and his wife, Susan Dell, and other employers' announcements of their own matching programs for the children of employees. However, the program is still in its early stages of development, so many details are still to come. While there is a clear intent at the federal level to move forward, much of the operational and administrative detail employers will need is not yet available.
At this point, Trump Accounts are best described as vaporware. Federal funding is not expected to begin until July 2026, and employers will not likely be able to fund accounts until the pilot program officially goes live on July 4, 2026. Until then, additional guidance is anticipated, but concrete implementation details remain limited.
Numerous vendors have indicated that they plan to support Trump Accounts; no provider has formally announced a fully operational offering. Large financial services firms—such as Fidelity and other major players in the retirement and investment space—are expected to participate once the framework is finalized, given the long-term nature of the assets involved.
The Internal Revenue Service has issued preliminary guidance in the form of Q&As under Notice 2025-68, which offers an early outline of how Trump Accounts are expected to function. While helpful, this guidance is high-level and leaves many employer-specific questions unanswered.
From the Notice 2025-68, several important points emerge:
The statutory language and early IRS commentary reference Trump Accounts in a manner similar to IRAs. We would expect, therefore, that the final rules may resemble elements of both the IRA and 401(k) frameworks.
Employers are expected to be able to contribute to Trump Accounts without including those amounts in employees' taxable income, though final confirmation and reporting mechanics are still forthcoming. The IRS has indicated that additional reporting guidance will be issued as the program matures.
One open question raised by some employers is whether employees (or parents, in applicable cases) will be able to make pre-tax or deductible contributions through payroll. The guidance indicates that it will be possible, but there is no detailed discussion of the administrative process for that.
In addition, it is expressly stated that employers can make non-taxable contributions, including those made through a cafeteria plan, are intended to be permitted. Further clarification will be required before employers can design compliant payroll and benefit integrations.
The IRS has provided some early direction on allowable investments within Trump Accounts. It is important to note that the entire universe of potential investments is limited. Permitted investments include mutual funds or ETFs that invest in an index that is primarily invested in U.S. stocks and futures that are traded on an exchange. It does NOT include industry-specific indices.
Account holders are expected to have some ability to adjust investment strategies. The extent of that flexibility—and the tools that will be available to participants—has not yet been defined.
For individuals, the IRS has already released:
While these materials provide insight into the individual contribution process, they do not address the employer-level questions that are currently top of mind for plan sponsors.
Trump Accounts remain a work in progress. Employers should expect additional guidance as the July 2026 pilot date approaches, including clarification on payroll integration, cafeteria plan treatment, nondiscrimination testing, reporting mechanics, and vendor readiness.
As more details are released and service providers formally enter the market, employers will be better positioned to evaluate whether—and how—to incorporate Trump Accounts into their broader benefits strategy. For now, employers should continue to monitor the ongoing announcements and keep expectations (particularly for employees) measured.
More guidance is expected, and more options should become available as the regulatory framework and vendor landscape continue to evolve.