Section 128 Trump Account Employer Readiness Checklist

Considering employer contributions to Trump Accounts?

Before launching a Section 128 Trump Account contribution program, employers must address more than the contribution amount. Implementation may involve a separate written program, eligibility rules, payroll controls, employee certifications, trustee coordination, nondiscrimination testing, corrections, notices, and year-end reporting.

This free employer readiness checklist helps HR, payroll, benefits, accounting, management, and professional advisers identify the decisions and operational workstreams that need attention.

The checklist covers:

• Program objectives and internal ownership

• Written-program requirements

• Eligibility and contribution rules

• The $2,500 employee-level annual limit

• Nondiscrimination considerations

• Employee certifications and data handling

• Trump Account and trustee verification

• Payroll controls and contribution reconciliation

• Employee notices and annual reporting

• Error correction and escalation procedures

• A readiness snapshot for identifying unresolved workstreams

This five-page checklist reflects federal guidance available through September 6, 2026, including the Treasury Department and IRS proposed regulations published in the Federal Register on August 11, 2026, the correction published on August 24, 2026, and a dated September 2026 proposed-rule addendum.

Important regulatory status: The detailed Treasury and IRS regulations governing Section 128 employer contribution programs are currently proposed and may change before being finalized.

Need the complete implementation system?

The Syntera Systems Trump Account Employer Implementation Kit includes an implementation roadmap, written-program checklist, payroll and contribution workbook, employee certification form, employee notice, annual statement template, and additional administrative tools.

Learn more: https://synterasystems.com/trump-account-kit.html

This checklist provides educational and administrative information only. It does not constitute legal, tax, investment, payroll, benefits, or individualized professional advice.