Overview
Individual retirement account (IRA) owners have deadlines by which many IRA-related “actions” must be completed. Furthermore, IRA custodians/trustees have deadlines to complete reporting. Transactions subject to a specific deadline include making an IRA regular contribution, removal of an excess or unwanted regular contribution, recharacterization of a prior year regular contribution, and completing a rollover or conversion after taking a distribution. A federally declared disaster area designation can provide relief (i.e., an extended deadline) to affected taxpayers, allowing them to complete certain transactions by a later specified date. Extending the deadline by which an IRA custodian or trustee must file certain reports, such as Internal Revenue Service (IRS) Form 5498, IRA Contribution Information, is also included in the relief provided by the IRS. For more information see the IRS 2025 Instructions for Forms 1099-R and 5498 or the Individual Retirement Accounts: 2025 contribution reporting on IRS Form 5498 article on Expert Insights.
Examples of extended deadline relief
The deadline for an individual to make an IRA regular contribution is his/her tax-filing due date, excluding extensions. For 2025 this deadline was April 15, 2026. The deadline by which an IRA custodian or trustee is required to file its 2025 Form 5498s with the IRS and provide a copy to IRA owners and beneficiaries is June 1, 2026.
Example 1: Jane, age 48, wants to make a $7,000 traditional IRA regular contribution for tax year 2025. Under normal circumstances, Jane would have been required to make this contribution by April 15, 2026, her 2025 tax filing deadline. However, because Jane is a resident of a county in Hawaii that was declared a disaster area due to flooding and mudslides resulting from severe storms beginning on March 10, 2026, she has until July 8, 2026, to make her 2025 IRA contribution.
Example 2: Jane, from example 1, has an IRA with ABC Bank. Utilizing the disaster declaration extension, Jane contributes $7,000 for 2025 to her traditional IRA with ABC Bank on June 14, 2026. How will ABC Bank report this contribution? ABC Bank is an IRA custodian located in a county in Hawaii that was declared a disaster area due to flooding and mudslides as the result of severe storms beginning on March 10, 2026. As a result, ABC Bank has an extended deadline of July 8, 2026, to file its 2025 IRS Form 5498s with the IRS and provide copies to IRA owners and beneficiaries. However, on these 2025 Form 5498s, ABC Bank will only report IRA regular contributions for 2025 made by IRA owners through April 15, 2026, in addition to other various contributions (e.g., rollovers, conversions, etc.) made to IRAs during 2025. Because the contribution Jane made on June 14, 2026, was for 2025 but was made using a disaster declaration extension, it is considered a postponed contribution for 2025 and will not be reported on a 2025 Form 5498 for 2025. ABC will collect deposit documentation from Jane indicating the deposit type as a postponed contribution, the tax year for which it was deposited (2025), and a reason code of why the contribution was postponed. In this case the reason code is ‘FD’ due to the postponed contribution relating to a federally designated disaster area. This postponed IRA regular contribution will be reported in boxes 13a, b, and c of Jane’s 2026 IRS Form 5498.
Example of rollover relief
Susan took $40,000 from her IRA on February 10, 2026. She was planning to roll the distribution back into an IRA within the 60-day time-period (i.e., by April 11, 2026). As a resident of a county in the state of Mississippi that was declared a federal designated disaster area due to the severe winter storm beginning on January 23, 2026, Susan has through June 8, 2026 to complete a rollover.
Conclusion
IRA custodians and trustees are not responsible for determining if someone is an affected taxpayer under disaster relief. However, with the many disaster declarations already made this year, understanding the rules and requirements to properly document and report various related transactions is a primary responsibility for IRA custodians and trustees.
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