
The U.S. Department of the Treasury and the IRS recently issued temporary and proposed regulations that allow the Treasury Department to establish Trump accounts automatically for eligible children who do not already have one (referred to as “auto accounts”). Auto enrollment represents an impactful pivot from earlier guidance, in which the Treasury Department and the IRS said they would not use automatic enrollment because of legal and operational concerns.
Auto accounts may be established for any eligible child who does not already have a Trump account opened on their behalf. This is regardless of whether the child is eligible for the $1,000 federal pilot program contribution (i.e., born between January 1, 2025, and December 31, 2028).
The Treasury Department completed the first round of automatic enrollments on October 1, 2026. Future rounds will be completed periodically for eligible children who do not yet have a Trump account.
Auto accounts may receive only general qualified contributions (i.e., contributions from a charity, state government or tribal government) and, in limited circumstances, the $1,000 pilot program contribution (e.g., if the pilot program contribution is elected but a Trump account has not been established). However, an eligible child’s guardian or legal custodian must still make an election to receive the pilot program contribution regardless of whether an auto account has been established. Once claimed by the guardian or legal custodian, the account becomes a "claimed initial Trump account" and may receive Internal Revenue Code section 128 employer contributions, pre-tax employee contributions and other types of permissible Trump account contributions.
Going forward
The regulations will not directly affect employers because an auto account may not receive section 128 employer contributions or pre-tax employee contributions until it is claimed and becomes a claimed initial Trump account.
Nevertheless, automatically enrolling eligible children into Trump accounts removes one of the primary barriers to participation and has significantly expanded the number of children with Trump accounts. As a result, employers may see more employee interest in Trump account programs.




