Does a Roth Conversion Count as an RMD? IRS Rules 2026

No, a Roth conversion does NOT satisfy a Required Minimum Distribution. If you're age 73 or older and have a traditional IRA subject to RMDs (per IRC §401(a)(9) and SECURE 2.0 §107), you must take the RMD first as an actual distribution to yourself. Only AFTER the RMD is satisfied can you convert additional traditional IRA dollars into a Roth IRA. Converting BEFORE the RMD is taken creates an excess contribution problem under IRC §408A(d)(3)(B). The IRS clarified this in Notice 2002-12.

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Quick Facts

warningRMDs and conversions are governed by separate IRC sections. RMDs: §401(a)(9). Conversions: §408A(d)(3). They don't satisfy each other.
infoRequired order: RMD first, conversion second. Take and report the RMD distribution to yourself, then any additional amount can be converted.
warningConverting before satisfying the RMD creates an excess Roth contribution. The amount equal to the unsatisfied RMD is treated as a contribution, exposing you to the 6% §4973 excise.
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 a Conversion Doesn't Satisfy an RMD

The Required Minimum Distribution rules under IRC §401(a)(9) require that a portion of your traditional retirement account be distributed to YOU (or to a beneficiary) each year starting at your applicable RMD age. The dollars must leave the tax-deferred account and become available for spending.

A Roth conversion, defined under IRC §408A(d)(3), is a transfer from a traditional IRA to a Roth IRA. The dollars don't become available to spend — they move from one tax-advantaged account to another. The IRS treats this as failing to satisfy the RMD requirement because no distribution-to-yourself occurred.

IRS Notice 2002-12 explicitly addressed this: "An RMD is considered to be the first amount distributed to the individual during the year, even if the individual subsequently converts amounts to a Roth IRA." In practical terms: any distribution you take in an RMD year is automatically counted toward the RMD first, and the rest can be converted.

The Correct Procedure for RMD-Year Conversions

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

Step 1. Calculate the RMD using the 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 distribution from the traditional IRA — typically wired to your checking account or held as cash. Income tax withheld at custodian's default (usually 10%) unless you elect otherwise.
Step 3. THEN convert any additional amount from the traditional IRA to a Roth IRA. This second transaction is the conversion. The conversion amount is included in your taxable income for the year, just like the RMD.
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 if direct trustee-to-trustee), plus Form 8606 to document the conversion and any after-tax basis.

Why Converting an RMD Improperly Causes Problems

If you ignore the RMD and instead try to convert your full IRA balance to a Roth, the IRS treats the dollars equal to the unsatisfied RMD as an EXCESS Roth contribution:

The RMD requirement is unmet — exposing you to a 25% excise tax under IRC §4974 on the missed RMD (reduced to 10% if corrected timely under SECURE 2.0 §302).
The "converted" RMD amount is treated as a regular Roth contribution — exposing you to 6% per year under IRC §4973 on the excess until removed.
Both penalties can stack until the situation is corrected.

Correcting requires a return-of-excess-contribution from the Roth IRA (custodian-coordinated) plus filing Form 5329 to either pay the §4974 excise or request the SECURE 2.0 waiver if the RMD was missed inadvertently and the situation was corrected timely.

Frequently Asked Questions

Can I convert my RMD to a Roth IRA?

No, not directly. The RMD must first be distributed to you as a taxable cash distribution. After the RMD is satisfied, you can convert any additional traditional IRA dollars to a Roth IRA. The RMD amount itself cannot be "converted" — it has to leave the tax-deferred system as a distribution.

What if I forgot to take the RMD before converting?

You have an excess Roth contribution and an unsatisfied RMD. Contact your custodian to process a corrective distribution from the Roth IRA equal to the RMD amount. File Form 5329 with your tax return — you'll either owe the §4974 excise (25%, reduced to 10% if corrected within the SECURE 2.0 §302 window) or can request a waiver if the failure was due to reasonable error.

Does a QCD count toward my RMD?

Yes — Qualified Charitable Distributions (QCDs) from a traditional IRA do satisfy the RMD up to the QCD annual limit ($111,000 for 2026 per IRS Notice 2025-67). QCDs are a different tool than conversions; they go directly from the IRA to a qualified charity and reduce taxable income while satisfying the RMD.

If I do a 401(k)-to-Roth-IRA rollover in an RMD year, does the rollover satisfy the RMD?

No, with the same logic. If you're 73+ and have an RMD due from your 401(k), you must take that RMD as a distribution before rolling over the remaining balance. Rolling over without first taking the RMD creates an excess contribution to the receiving Roth IRA equal to the RMD amount.