An RMD cannot be rolled over or converted to a Roth IRA. If a required minimum distribution is due from your traditional IRA, satisfy it before converting additional eligible money. The rule does not require a cash-only withdrawal. If RMD money was mistakenly sent to a Roth IRA, the distribution and the Roth contribution must be analyzed separately — two penalties do not arise automatically.

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Quick Facts

  • check_circleRMD amounts are not eligible rollovers. IRC §408(d)(3)(E) excludes them.
  • check_circleTake the RMD before the conversion. The first IRA distributions of an RMD year count toward that year's required amount.
  • check_circleA mistaken Roth deposit is not automatically a missed RMD. The regulation treats the RMD portion as distributed, then contributed as a regular Roth contribution.
  • check_circleRoth IRA owners have no lifetime RMDs. The exemption is IRC §408A(c)(4); beneficiaries have separate rules.
  • check_circleCheck the actual year's requirement. Birth year, account type and first-year deadlines matter; workplace plans can have additional retirement-related rules.

Why an RMD Cannot Be Converted

The restriction is about rollover eligibility, not whether money passes through your checking account. A Roth conversion is itself treated as a distribution from the traditional IRA. But the portion needed to satisfy an RMD cannot be a conversion contribution.

Treasury Regulation §1.408A-4, Q&A-6(a)–(c) explains both the RMD-first rule and a mistaken Roth deposit. Notice 2002-12 is not the source for this rule. The regulation's old age and income-limit references elsewhere must be read in light of later law; they are not current conversion eligibility limits.

The Procedure for an RMD-Year Conversion

  1. Calculate the required amount. For an owner's ordinary IRA RMD, generally divide the prior December 31 balance by the applicable IRS table factor. Most owners use the Uniform Lifetime Table; use the Joint Life and Last Survivor Table when the sole beneficiary is a spouse more than 10 years younger. Beneficiary rules differ.
  2. Arrange the RMD distribution first. Cash is common, but a custodian may also distribute investments in kind, valued when distributed. Consider any withholding separately from the amount counted as distributed.
  3. Convert additional eligible IRA money. Only the taxable part is included in income. Nondeductible basis is allocated under Form 8606; a conversion is not necessarily fully taxable.
  4. Reconcile the tax forms. The custodian reports distributions on Form 1099-R. An IRA-to-Roth-IRA conversion generally uses code 2 before age 59½ or code 7 at/after that age, not code G merely because it was trustee-to-trustee. Use Form 8606 for the IRA conversion and any required basis calculation.

Taxable amounts can affect other income-based calculations, including Medicare premiums and Social Security taxation. A qualifying charitable distribution may satisfy an RMD without the usual income inclusion. The right calculation depends on your whole return, not just the transfer amount.

If the RMD Was Sent to the Roth by Mistake

Under Q&A-6(c), the RMD portion is treated as a traditional IRA distribution and then a regular Roth IRA contribution, not a conversion. That contribution must fit the ordinary compensation, MAGI and shared IRA-limit rules. An ineligible amount can be an excess contribution; it is not automatically excess if the ordinary contribution requirements are met.

Contact the custodian and your tax preparer promptly. If there is an excess, a timely return of the excess and attributable net income can prevent the annual 6% excess-contribution tax; the usual deadline is the return due date including extensions. Do not simply withdraw an arbitrary amount or describe a valid conversion as reversible.

A separate missed-RMD excise applies only to an actual shortfall by the applicable deadline. It is generally 25%, potentially 10% if the statutory correction-window conditions are met; reasonable-error waiver relief may also be available. Which parts of Form 5329 are needed depends on what actually happened. Removing the Roth excess does not create a second RMD or automatically repair a different year's shortfall.

Sources: Publication 590-A, conversions and excess contributions; Publication 590-B, RMDs and QCDs; Form 5329 instructions, Parts IV and IX; Forms 1099-R/5498 instructions, IRA conversions and distribution codes; Notice 2025-67, 2026 QCD limit. Publication 590 and Form 5329 references are the 2025 editions; the 1099-R instructions checked are for 2026.