Trump accounts launched in July 2026, and federal agencies have begun issuing guidance on how the accounts will work. Most notably for employers, the U.S. Department of Labor (DOL) issued Technical Release 2026-02, explaining that employer contribution programs for employees’ dependent children generally will not be treated as ERISA-covered plans.

Why it matters: The guidance gives employers a clearer path to consider Trump account contributions as part of their employee benefit offerings. Still, it is informal guidance, so some employers may wait for more formal DOL rulemaking or additional Internal Revenue Service (IRS) instructions before moving forward.

What’s next: The Trump administration is focused on promoting awareness of Trump accounts, signing up more children, accepting contributions from multiple sources and adding app functionality for parents and guardians. As of July 21, 2026, the White House is reviewing a soon-to-be-published proposed rule on eligible investments for Trump accounts.

What are Trump accounts?

Trump accounts are traditional IRAs for eligible children with special rules during the account’s “growth period,” including limits on investments, contributions and distributions. Learn the basics from an earlier blog.

This blog focuses on employer contributions for employees’ dependent children, not accounts for teenage employees.

What is the growth period?

The growth period ends before January 1 of the year the beneficiary turns 18. For example, a child born October 1, 2025, turns 18 on October 1, 2043, so the growth period ends December 31, 2042.

What has happened around launch?

• July 1, 2026: Treasury named one initial default investment fund available at launch plus four other funds expected to be available later. The default is the State Street SPDR Portfolio S&P 500 ETF (SPYM), a low-cost ETF that tracks the S&P 500 Index. The fund was selected to provide broad exposure to the U.S. stock market while maintaining expenses well below the statutory fee limitation. Treasury will announce when investment election functionality becomes available and instruct parents and guardians to change an account’s investment allocation.
• July 2, 2026: Treasury began accepting donations of publicly traded company stock to support Trump accounts. Donors can transfer approved publicly traded stock to Treasury so it can be contributed to Trump accounts based on donor preferences as well as applicable laws and regulations.
• July 3, 2026: The Social Security Administration said it will assist states in modifying hospital forms used by parents to apply for Social Security numbers through the Enumeration at Birth program so the forms can include automatic creation of a Trump account.
• July 4, 2026: Treasury announced the official launch and said more than 50 companies had committed to offer Trump account contributions for children of their employees. Parents can use the Trump accounts app to set recurring contributions from a bank account.

For employers, the launch and promotional news is important—but the practical question is how contributions can be administered.

Are employer contribution programs subject to ERISA?

Generally, no—for employer contributions to Trump accounts for employees’ dependent children during the growth period. DOL Technical Guidance 2026-02 says that ERISA pension plans provide retirement income to employees, while these accounts generally benefit children who do not work for the employer.

Employers should still be cautious. DOL’s guidance is helpful but informal, and employers may want to see similar language in proposed or final regulations before relying on it.

When can employer contributions begin?

Not yet in a fully operational way. And we don’t know an exact date. Employers are still waiting for guidance and infrastructure to move contributions from payroll or employer systems into Trump accounts. A recent PLANSPONSOR column noted that Trump accounts generally sit outside the retirement plan framework because current law and guidance do not create a way to include them in a retirement plan.

What operational questions remain?

Employers still need guidance on how to process payroll, how employee salary deferrals and employer contributions are transmitted to a Trump account and how contributions should be allocated when an employee has multiple dependents with accounts. They also need to know whether they will be notified when an account nears its annual contribution limit. Employers are also waiting for possible vendor support capabilities.

What compliance issues remain?

DOL’s technical guidance says requirements similar to Internal Revenue Code section 129 dependent care assistance program rules will apply to a Trump account employer contribution programs. That includes nondiscrimination rules for contributions, benefits, eligibility and average benefits, plus employee notices and benefit statements.

What is the bottom line for employers?

DOL’s ERISA guidance on Trump account contributions addresses one concern. But administrative details still matter. Until more guidance is available, employers may choose to monitor DOL and IRS updates, watch what other employers are doing and gauge vendor readiness before launching a program.

Developed by International Foundation Information Center staff. This does not constitute legal advice. Please consult your plan professionals for legal advice.