Proposed IRS rules open cafeteria plan route for Trump Account contributions
IRS proposed rules open a Section 125 pathway for dependent Trump Accounts, giving benefits advisors an open enrollment season role
Proposed IRS rules open cafeteria plan route for Trump Account contributions
GROUP BENEFITS
By Mark Rosanes
Oct 09, 2026

More than 60 million American children were auto-enrolled in Trump Accounts when the program formally launched this week, and with open enrollment season underway, the question of whether and how to participate is now in front of employers. The White House marked the milestone Thursday, with President Donald Trump joined by Treasury Secretary Scott Bessent and Internal Revenue Service (IRS) chief executive Frank Bisignano.

The regulations are proposed and have not yet been finalized. Employers should confirm final rule status before implementing a program.

Since the accounts began accepting contributions on July 4, more than $4.5 billion has been deposited, including $1.3 billion in $1,000 government seed contributions, $600 million in family contributions, and $2.6 billion in philanthropic gifts, largely from the Michael and Susan Dell Foundation’s $6.25 billion commitment.

Trump Accounts, created under the One Big Beautiful Bill Act, are tax-advantaged investment accounts established for every American child under 18 with a valid Social Security number. Families, employers, and philanthropists can all contribute. The government’s $1,000 seed contribution does not count against the annual limit. Family contributions are capped at $5,000 per year per child, with employers permitted to contribute up to $2,500 within that cap.

What the IRS guidance confirms

The most operationally significant development for employer-sponsored programs came in August, when the Treasury Department and IRS issued proposed regulations under Internal Revenue Code Section 128 governing employer contributions to Trump Accounts. The regulations confirmed that employees can make pre-tax contributions to a dependent child’s Trump Account through a Section 125 cafeteria plan. That same structure governs health flexible spending accounts, dependent care accounts, and other pre-tax employee elections that benefits advisors already administer.

The proposed rules do draw one important boundary. The cafeteria plan salary reduction applies only to contributions to a dependent’s account, rather than the employee’s own. Employers wishing to facilitate employee contributions to their own Trump Accounts must do so outside the Section 125 framework.

Three employer contribution designs have emerged from the guidance: a direct employer contribution up to $2,500, a $1,000 match of the federal seed contribution, or a Section 125 salary reduction feature that lets employees direct pre-tax dollars to a dependent’s account without the employer making a direct contribution at all. That third option is where the cafeteria plan architecture becomes most relevant to advisors already administering those plans.

Melissa Elbert, wealth solutions partner at Aon, said that last option is particularly worth noting. “One of the more notable clarifications is Treasury’s continued support for the Section 125 cafeteria plan model for dependent Trump Account contributions,” Elbert said. “For employers, that preserves a potentially important middle ground: the opportunity to facilitate participation through existing benefits infrastructure, even if they choose not to make direct contributions themselves.”

A financial wellbeing add-on at open enrollment

The launch lands during open enrollment season and connects directly to a financial pressure employers are already navigating. Finances are the leading source of stress for Americans in 2026, with more than half of US adults identifying finances as a major or primary stressor, according to Lincoln Financial’s Financial Stress Loop 2026 Insights Brief.

Trump Accounts add a family-focused savings dimension to a benefits package, one that brokers are increasingly being asked to help employers build out as financial wellbeing moves from a supplemental offering to a core retention tool.

A February 2026 Mercer poll found roughly 16% of employers already plan to offer Trump Account funding or are actively considering it, with about 30% still undecided. That still leaves a significant share of the market evaluating the decision. The comment period closed September 15.

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