While millions of children have already been signed up for Trump Accounts, some experts participation in the tax-advantaged program could be less equal than retirement savers would like.
More than 6 million children have been signed up for Trump Accounts as of mid-June, according to a tally from the U.S. Department of the Treasury.
But compared to the roughly 73.1 million children under 18 in the United States, per 2024 Census Bureau data, that's still far short of the actual number of Americans that would qualify for the tax-advantaged investment accounts.
The accounts, created under the One Big Beautiful Bill Act (OBBBA) signed in July last year, allow parents, guardians, grandparents, employers, and charitable organizations to contribute up to $5,000 annually to tax-deferred investment accounts in a child's name.
Children born between January 1, 2025, and December 31, 2028, who are U.S. citizens are eligible for a one-time $1,000 seed contribution from the Treasury Department, with accounts set to officially go live and begin accepting private contributions on July 4.
Among the 6 million-plus enrolled children, roughly 1.4 million qualify for the $1,000 Treasury pilot contribution, according to the latest published data. That figure, reported by CNBC, represents only about 39% of the children who would be eligible for the seed money.
According to the Treasury's June 2026 figures, 86% of Trump Accounts opened are linked to families earning less than $200,000 annually. Yet approximately 95% of U.S. households with children under 18 fall below that income threshold, based on 2024 Census data, suggesting at least a slight overrepresentation of higher-income families among early adopters.
Madeline Brown, senior policy associate at the Washington-based Urban Institute, pointed to the program's opt-in structure as a core barrier.
"So the question leading into July, when money will actually get deposited, is whether low-income families, low-wealth families and those without means to invest on behalf of their children are in the group who have signed up or the larger group that hasn't," she told CNBC.
In a recent analysis, Adam Michel, director of tax policy studies at the Cato Institute, argued that the program's reliance on families opting in will lead to "a system used primarily by those best equipped to navigate it."
The analysis also flagged that accounts will contain a mix of pre-tax and after-tax dollars, meaning pre-tax funds will be subject to ordinary income taxes at withdrawal and a 10% penalty if taken before age 59½ – a wrinkle that could further dampen participation among households with limited financial literacy.
Trump Accounts function as a hybrid between a traditional individual retirement account (IRA) and a custodial investment account. During the "growth period" – which runs from account establishment through December 31 of the year before the beneficiary turns 18 – contributions are restricted to eligible index funds of primarily U.S. companies, distributions are generally prohibited, and no deduction is available for contributions made.
Employers can kick in up to $2,500 per employee annually, which would count toward the $5,000 aggregate annual contribution cap. Contributions from state and local governments, tribal governments, and qualifying nonprofits do not count against the $5,000 limit. After the growth period ends, the accounts convert to standard traditional IRA rules.
Major companies including JPMorgan Chase, Intel, and Steak 'n Shake, along with Robinhood and Schwab, have pledged to match the Treasury's $1,000 contribution for employees' children born between 2025 and 2028.
Philanthropist Michael Dell and his wife, Susan, committed $6.25 billion to provide an additional $250 for children born before 2025 who live in ZIP codes where median income is $150,000 or less.
Based on modeling by the Schwab Center for Financial Research in November, an account receiving the $1,000 Treasury seed plus maximum annual parental contributions – starting at $5,000 and adjusted for inflation – could grow to approximately $191,000 by age 18 and potentially more than $2.2 million by age 60, assuming a 6% annual growth rate.
As employers begin evaluating whether to offer Trump Account contributions as an employee benefit, the U.S. Department of Labor's Employee Benefits Security Administration recently issued technical guidance confirming that Trump Accounts and related employer contribution programs will generally not constitute "employee pension benefit plans" subject to Title I of ERISA.
The DOL's guidance addressed the gap left when Congress enacted the OBBBA without explicitly clarifying whether employer contributions under Internal Revenue Code Section 128 – which allows employers to make tax-favored contributions to a child's Trump Account, excluded from the employee's gross income – would trigger ERISA obligations.
The agency concluded they generally will not, citing the fundamental structure of the accounts: they are established for the benefit of dependents, not employees themselves, and employers exercise no meaningful control over account administration or investment decisions. The Treasury Department – not employers – creates the initial accounts, and investments during the growth period are strictly governed by the tax code.
"This guidance should provide the clarity that employers need as the Administration rolls out Trump Accounts to jumpstart a golden age of investing in future generations," Acting Secretary of Labor Keith E. Sonderling said in a statement accompanying the release.
However, the technical release acknowledged an edge case where an employee – rather than a dependent – is the account beneficiary, such as a 16- or 17-year-old worker.
In those cases, EBSA said employer contributions will not create an ERISA plan provided participation is completely voluntary and the employer does not control investments, restrict fund use beyond what the tax code permits, represent the arrangement as an ERISA benefit plan, or receive compensation related to the account.
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