Yes. Form 5329 reports a missed required distribution even when no distribution—and therefore no Form 1099-R—occurred that year. First establish that an annual RMD was actually required under the beneficiary rules. This answer assumes a genuine 2025 shortfall, not simply an account subject to a ten-year depletion deadline.
Use the 2025 Form 5329 for that shortfall. A corrective withdrawal made in 2026 is generally reported as distribution income for 2026, subject to the account’s applicable taxable and nontaxable treatment. Do not invent a 2025 Form 1099-R.
Reasonable error and reasonable steps to remedy the shortfall may support a waiver request, with an explanation; IRS approval is not automatic. Otherwise, the additional tax generally is 25%, potentially 10% when both correction-window requirements are met. Prior-return status and other changes determine the filing route; follow the prior-year and amended-return instructions.
Primary sources
Instructions for Form 5329 (2025) | Internal Revenue Service
Required minimum distributions for IRA beneficiaries | Internal Revenue Service