Can an RMD Be Transferred Into a Roth IRA? IRS Rules 2026

No. Required Minimum Distributions under IRC §401(a)(9) must be taken as cash before any traditional-to-Roth conversion — the RMD dollars cannot be rolled over (Notice 2002-12). Trying to convert before satisfying the RMD creates an excess Roth contribution, exposing you to both the 25% RMD-failure excise (IRC §4974) and the 6% excess-contribution excise (IRC §4973).

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Quick Facts

warningRMDs cannot be converted. They must leave the tax-deferred system as cash to you.
infoRequired order: RMD first as a regular distribution, then any additional amount can be converted.
warningConverting an unsatisfied RMD creates double penalties: §4974 RMD failure excise (25%, reduced to 10% if corrected per SECURE 2.0 §302) PLUS §4973 excess Roth contribution excise (6% per year).
check_circleRoth IRA owners have no lifetime RMDs per IRC §408A(c)(5). The RMD-first rule only applies if you're taking from a traditional IRA, SEP-IRA, SIMPLE IRA, or pre-2024 Roth 401(k).
infoRMD age: 73 for those born 1951–1959; 75 for those born 1960 and later (SECURE 2.0 §107).

Why the IRS Treats RMDs This Way

The Required Minimum Distribution rules under IRC §401(a)(9) and the regulations under TD 10001 (July 2024) require that a portion of your tax-deferred retirement balance be DISTRIBUTED to you each year starting at your applicable RMD age. The dollars must leave the tax-advantaged system and become available for spending — that's the point. The IRS wants those dollars taxed in your lifetime, not deferred indefinitely.

A conversion under IRC §408A(d)(3) is a transfer between two tax-advantaged accounts (traditional IRA → Roth IRA). The dollars don't leave the retirement system; they just move buckets. The IRS treats this as failing to satisfy the RMD because no distribution-to-yourself happened.

IRS Notice 2002-12 explicitly addressed this: any distribution you take from a traditional IRA in an RMD year is automatically counted toward the RMD first. Only after the RMD is fully satisfied can additional dollars be converted.

The Correct Procedure for an RMD-Year Conversion

If you want to do BOTH an RMD and a Roth conversion in the same year:

Step 1. Calculate the RMD using your December 31 prior-year balance and the applicable life-expectancy divisor (Uniform Lifetime Table for most owners; Joint Life and Last Survivor Table if your sole beneficiary is a spouse more than 10 years younger).
Step 2. Take the RMD as a normal cash distribution from the traditional IRA. Custodian default withholding is 10% federal — change to 0% if you'll cover the tax separately.
Step 3. THEN convert any additional amount you want from the traditional IRA to a Roth IRA. This is a separate transaction and is taxable as ordinary income in the conversion year.
Step 4. Report both on your tax return. RMD: Form 1099-R with code 7 (normal distribution). Conversion: Form 1099-R with code 7 or G (direct trustee-to-trustee), plus Form 8606 to document.

Both the RMD and the conversion increase your taxable income for the year. Plan for the combined tax impact: federal bracket, state tax, IRMAA tier, ACA subsidy, NIIT exposure, Social Security taxation. Run the True Cost of a Conversion tool with your numbers.

What Happens If You Got the Order Wrong

If you initiated a conversion BEFORE taking the RMD, you have two problems simultaneously:

The RMD is unmet. The first dollars distributed in any RMD year are deemed RMD per Notice 2002-12. By converting, no dollars actually distributed to you (the conversion isn't a distribution-to-self). The RMD remains owed. This triggers IRC §4974 excise: 25% of the missed RMD amount, reduced to 10% if corrected within the SECURE 2.0 §302 window (generally 2 years after the year of failure).
The amount equal to the unsatisfied RMD is treated as an excess Roth contribution under IRC §408A(d)(3)(B). This triggers §4973 excise: 6% of the excess per year until removed.

Correction procedure:

Contact the Roth IRA custodian to process a corrective distribution from the Roth IRA equal to the unsatisfied RMD amount (plus attributable earnings).
That distribution then satisfies the original year's RMD requirement (handled as a deemed RMD under Notice 2002-12 logic).
File Form 5329 with your tax return to either pay the §4974 excise (10% if corrected timely) or request a waiver for reasonable cause.
File Form 5329 to also report the excess Roth contribution removal.

Frequently Asked Questions

Can I take my RMD and then convert the same dollars?

No — once the RMD is taken as a cash distribution, those dollars are out of the tax-advantaged system. You cannot "re-deposit" them into a Roth IRA via conversion. You CAN take the RMD and then separately convert ADDITIONAL traditional IRA dollars (above the RMD amount) — that's the standard procedure for combining both.

Does a QCD satisfy my RMD if I want to do a conversion later?

Yes. Qualified Charitable Distributions (QCDs) under IRC §408(d)(8) satisfy your RMD up to the QCD annual limit ($111,000 for 2026 per IRS Notice 2025-67). After QCD-satisfied RMD, you can convert any additional amount from the traditional IRA to a Roth without RMD-related issues. QCDs go directly from the IRA to a qualified charity and don't increase your taxable income.

If I have multiple traditional IRAs, can I take the RMD from one and convert from another?

Yes — RMDs from traditional IRAs are aggregated under IRC §408(a)(6). You can satisfy the total RMD by taking it from any single traditional IRA, then convert from any other traditional IRA. The IRS treats traditional IRAs as one pool for RMD purposes, but each conversion event is account-specific.

Does this rule apply to Roth IRA-to-Roth IRA transfers?

No. Roth IRAs have no lifetime RMDs (IRC §408A(c)(5)), so the RMD-first rule simply doesn't apply to your own Roth IRAs. You can do trustee-to-trustee transfers between Roth IRAs at any time without RMD considerations. Inherited Roth IRAs may have distribution requirements (10-year rule), but those are tracked separately.