DOL Clarifies ERISA Treatment of Trump Accounts

Short summary

The DOL issued Technical Release 2026-02 clarifying that Trump Accounts—new IRAs for individuals under 18 created under the One Big Beautiful Bill Act—are generally not subject to Title I of ERISA. Accounts benefiting only dependents are not ERISA plans, and employer-contributed accounts can rely on an HSA-style safe harbor if participation is voluntary and employer involvement is limited. Employers should structure arrangements carefully to maintain safe harbor status.

• •DOL concludes Trump Accounts are generally not ERISA plans
• •Employer-contributed accounts can use HSA safe harbor if participation is voluntary
• •Employee-only contribution accounts can rely on IRA safe harbor

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