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

An amount required as an RMD cannot be a Roth conversion. In a year when an RMD is due from your traditional IRA, the first distributions count toward that required amount; only additional eligible money can be converted. If an attempted conversion includes the RMD, the RMD portion is treated as distributed and then as a regular Roth contribution — not automatically as an unpaid RMD.

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Quick Facts

check_circleRMDs cannot be rolled over. The controlling exclusion for IRAs is IRC §408(d)(3)(E).
check_circleRMD first, conversion second. Separate the required amount before arranging an eligible conversion.
check_circleA mistaken deposit requires two checks. Was the RMD distributed on time, and is the resulting regular Roth contribution permitted?
check_circleOriginal Roth owners have no lifetime RMDs. IRC §408A(c)(4) covers Roth IRAs; designated Roth workplace accounts have also been exempt since 2024.
check_circleAge alone does not answer every case. Account type, birth year, first-year timing and applicable workplace retirement rules matter.

Why the RMD Portion Is Not a Conversion

A conversion is treated as a distribution from a traditional IRA even when it moves directly between trustees. The problem is not that you never held the cash: the RMD portion is legally ineligible for rollover.

Treasury Regulation §1.408A-4, Q&A-6 says the first distributions are treated as RMDs until the required amount has been distributed. Its paragraph (c) separately addresses an RMD sent to Roth. The earlier attribution to Notice 2002-12 was incorrect. Do not use the regulation's older age or conversion-income references elsewhere as current limits; later laws changed those rules.

The Procedure for RMD-Year Conversions

Determine the RMD. An owner's ordinary IRA calculation generally uses the prior December 31 balance divided by the applicable IRS table factor. Most use the Uniform Lifetime Table; a sole-beneficiary spouse more than 10 years younger calls for the Joint Life and Last Survivor Table.
Satisfy the RMD first. Arrange the distribution with the custodian. It need not be cash-only; an in-kind distribution uses the distributed property's value. A qualifying direct charitable distribution may count toward the requirement.
Convert additional eligible money. An RMD and a conversion may each include nontaxable basis. Calculate their taxable portions rather than treating both gross amounts as automatically taxable.
Report the transactions. The custodian issues Form 1099-R; use Form 8606 for the traditional-IRA conversion and any applicable basis calculation. The IRA conversion code is generally 2 before 59½ or 7 at/after 59½. Code G is not the code for an IRA conversion just because the trustees transferred it directly.

If you own several traditional IRAs, calculate each RMD and generally satisfy the total from one or more of those IRAs. A 401(k) requirement is separate; an IRA withdrawal does not satisfy it. Inherited-account rules also need separate treatment.

If an Attempted Conversion Included the RMD

The required portion was distributed, but it was not validly converted. Q&A-6(c) treats it as a regular Roth contribution after the traditional IRA distribution. It must therefore fit your compensation, Roth MAGI and unused shared IRA contribution limit. An amount that does not qualify can create an excess Roth contribution.

Ask the custodian and your tax preparer to identify the amount and the appropriate correction. A timely return of an excess plus attributable net income can avoid the 6% annual excess-contribution tax; the ordinary deadline is the tax-return due date including extensions. A valid 2018-or-later conversion cannot simply be recharacterized back to traditional.

Do not assume a second, missed-RMD penalty. A §4974 excise concerns an actual RMD shortfall by its deadline. The general 25% rate may be reduced to 10% when the correction-window requirements are met, and reasonable-error waiver relief may be available. Form 5329 reporting depends on the actual excess or shortfall. A timely distributed RMD does not become unpaid solely because it was deposited in Roth.

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

Frequently Asked Questions

Can I convert my RMD to a Roth IRA?

No. The required amount is not an eligible rollover or conversion. Satisfy the RMD, then convert additional eligible traditional IRA money if desired. This does not mean that an RMD must be cash-only or that every dollar distributed is taxable; basis and qualified charitable distributions can affect the tax treatment.

What if I forgot to take the RMD before converting?

Do not assume you owe both an excess-contribution penalty and a missed-RMD penalty. The IRA regulation treats the required portion as distributed and then as a regular Roth contribution. Ask the custodian and tax preparer whether that contribution fits your eligibility and annual room, whether an excess needs timely correction, and whether any actual RMD shortfall remains.

Does a QCD count toward my RMD?

Yes, a qualifying direct payment from an eligible IRA to an eligible charity can count toward the year's RMD. You must be at least 70½ when paid. The 2026 exclusion ceiling is $111,000 per person, and deductible IRA contributions for years at age 70½ or older can reduce the exclusion. Follow the QCD conditions; a later personal charitable gift does not undo income from an earlier ordinary withdrawal.

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

The plan's RMD amount cannot be rolled over. If an RMD is due from that 401(k), have the plan separate it before rolling over the eligible remainder. Workplace rules can differ from IRA rules, including a possible still-working delay. Do not use an IRA distribution to satisfy a 401(k) RMD, or assume a nonspouse beneficiary can freely convert an inherited account.