A 529 to Roth IRA rollover lets you move unused 529 college savings into the plan beneficiary’s Roth IRA, tax-free and penalty-free, up to $35,000 over that beneficiary’s lifetime, with 2026 rollovers capped at $7,500 per year (or $8,600 at age 50 and older). The 529 to Roth IRA rollover rules for 2026 come from Section 126 of the SECURE 2.0 Act, which took effect January 1, 2024, and also require the 529 to have been open at least 15 years.
Under the 529 to Roth IRA rollover rules for 2026, leftover 529 funds can move into the beneficiary’s Roth IRA with no federal income tax and no 10% penalty. The lifetime cap is $35,000 per beneficiary; the 2026 annual limit is $7,500 (under 50) or $8,600 (50 and older). The 529 must be at least 15 years old, and contributions from the last 5 years are not eligible. (Source: SECURE 2.0 Act Sec. 126; savingforcollege.com, 2026)
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What are the 529 to Roth IRA rollover rules for 2026?
The 529 to Roth IRA rollover rules for 2026 are: a $35,000 lifetime cap per beneficiary; an annual cap equal to that year’s IRA contribution limit ($7,500 under 50, $8,600 at 50 and older), reduced by the beneficiary’s other IRA contributions; a 15-year minimum account age; a 5-year lookback excluding recent contributions; and the Roth IRA must belong to the 529 beneficiary, who needs matching earned income. The transfer must be direct trustee-to-trustee. (Source: SECURE 2.0 Act Sec. 126; savingforcollege.com, 2026)
For years, families hesitated to fully fund 529 college savings plans because of one worry: what if the child earns a scholarship, picks a cheaper school, or skips college entirely? Money left in the account could only come out for non-qualified reasons by paying income tax plus a 10% penalty on the earnings. Section 126 of the SECURE 2.0 Act created a new exit, often called a “safety valve” for overfunded or unused 529s. (Source: SECURE 2.0 Act Sec. 126; Kitces, 2026)
529 to Roth IRA rollover rules at a glance (2026)
| Rule | 2026 detail | Source |
|---|---|---|
| Lifetime cap | $35,000 per beneficiary, aggregated across all rollovers | SECURE 2.0 Sec. 126 |
| Annual cap | That year’s IRA limit: $7,500 (under 50) or $8,600 (50+), reduced by the beneficiary’s other IRA contributions | savingforcollege.com, 2026 |
| Account age (15-year rule) | 529 must have been maintained at least 15 years before any rollover | Fidelity, 2026 |
| 5-year lookback | Contributions (and their earnings) from the last 5 years are not eligible | savingforcollege.com, 2026 |
| Earned income | Beneficiary needs earned income at least equal to the amount rolled that year | Empower, 2026 |
| Who owns the Roth | The Roth IRA must belong to the 529 beneficiary, not the account owner | Fidelity, 2026 |
| Income limits | Roth MAGI phase-outs are generally understood not to apply | UBS; Empower, 2026 |
| Transfer method | Direct trustee-to-trustee transfer only | savingforcollege.com, 2026 |
529 rollover vs. Roth conversion: what’s the difference?
A 529 to Roth IRA rollover moves seasoned 529 funds into the beneficiary’s Roth IRA with no federal taxable income when the rules are met. A true Roth conversion instead moves pre-tax traditional IRA or 401(k) money into a Roth and creates ordinary taxable income in the conversion year. People search for a “529 to Roth IRA conversion,” but the SECURE 2.0 transaction is legally a rollover, not a taxable conversion. (Source: SECURE 2.0 Act Sec. 126; Kitces, 2026)
The terminology trips people up, so it is worth separating. A standard Roth conversion is a taxable event: you move pre-tax retirement dollars into a Roth and pay income tax on the amount converted, in exchange for tax-free growth afterward. A 529 to Roth IRA rollover produces no federal taxable income at all when the 15-year, 5-year, earned-income, and cap tests are satisfied. This article uses “conversion” the way searchers phrase it, but every rule below is a rollover rule. If you are weighing a taxable conversion of your own retirement accounts, our guide to how much to convert to a Roth covers that separate decision.
Who qualifies for a 529 to Roth IRA rollover?
To qualify for a 529 to Roth IRA rollover, the 529 must have been open at least 15 years, the funds being moved must have been in the account at least 5 years, the receiving Roth IRA must belong to the 529 beneficiary, and that beneficiary must have earned income at least equal to the rollover for the year. Each gate applies separately, and all must be met. (Source: SECURE 2.0 Act Sec. 126; savingforcollege.com, 2026)
The 15-year rule
The 529 account must have been maintained for at least 15 years before any funds move to a Roth IRA. This clock runs on the account, not on any single contribution. A plan opened when a child was born reaches eligibility around the time that child turns 15. (Source: Fidelity; savingforcollege.com, 2026) People search for the “529 15 year rule” and the “15 year rule for 529 to Roth,” and this is it: no 15 years of account history, no rollover.
The 5-year lookback
Separate from the account age test, any contribution made in the last five years, along with the earnings attributable to it, cannot be rolled over. Only money that has seasoned in the account for at least five years is eligible. A $5,000 deposit made in 2024, for example, is not available to roll until roughly 2029. This blocks families from funneling fresh cash through a 529 straight into a Roth. The five-year test looks at each contribution’s age, so it applies contribution by contribution, not to the account as a whole. (Source: savingforcollege.com; Empower, 2026)
Earned income requirement
The beneficiary needs compensation (earned income) for the year that is at least equal to the amount being rolled. If the beneficiary earns $4,000 from a job, only $4,000 can move that year even though the annual ceiling is higher. This mirrors the earned-income rule for ordinary Roth IRA contributions. (Source: SECURE 2.0 Sec. 126; savingforcollege.com, 2026)
The Roth IRA must belong to the beneficiary
The receiving Roth IRA has to be owned by the 529 beneficiary, not by the parent or grandparent who owns the 529. A parent cannot route a child’s 529 into the parent’s own Roth. If a grandparent owns the 529 for a grandchild, the grandchild is the one who receives the Roth. (Source: SECURE 2.0 Sec. 126; Fidelity, 2026)
What is the annual limit for a 529 to Roth IRA rollover?
The annual limit for a 529 to Roth IRA rollover equals that year’s IRA contribution limit: in 2026, $7,500 for a beneficiary under 50 or $8,600 at age 50 and older. That ceiling is reduced by any other traditional or Roth IRA contributions the beneficiary makes for the year, and it cannot exceed the beneficiary’s earned income. There is no way to move the full $35,000 in one year. (Source: savingforcollege.com; instead.com, 2026)
Critically, the rollover uses up the beneficiary’s own Roth contribution room for the year. If a 25-year-old beneficiary already put $3,000 into a Roth IRA in 2026, only $4,500 of 529 money can roll that year (the $7,500 limit minus $3,000). The annual cap is the single biggest reason reaching $35,000 takes multiple years, as the timeline below shows.
What is the lifetime limit for a 529 to Roth IRA rollover?
The lifetime limit for a 529 to Roth IRA rollover is $35,000 per beneficiary. That $35,000 cap is aggregated across every rollover and across every 529 account for that same person, so it is a per-beneficiary total, not a per-account or per-year figure. Once $35,000 has moved to the beneficiary’s Roth IRA over their lifetime, no further 529 to Roth rollovers are allowed for them. (Source: SECURE 2.0 Sec. 126; savingforcollege.com, 2026)
Two limits stack. The lifetime cap is $35,000 per beneficiary. The annual cap equals the beneficiary’s IRA contribution limit for the year. Because you can never move more than the annual limit in a single year, the $35,000 lifetime figure is best thought of as a multi-year target rather than a lump sum. Families weighing how to sequence this alongside other retirement moves may find our overview of how much to convert to a Roth useful for the broader picture.
How many years does it take to roll over the full $35,000?
At the 2026 annual limit of $7,500, rolling the full $35,000 takes at least five years (four years of $7,500 plus a final $5,000). It can take longer if the beneficiary makes other IRA contributions, has limited earned income in some years, or if annual IRA limits differ. You also cannot start until the 529 has been open 15 years. (Source: savingforcollege.com; Fidelity, 2026)
The table below is a hypothetical timeline for a 529 opened the year a child is born, assuming the beneficiary has at least $7,500 of earned income each eligible year, makes no other IRA contributions, and that the annual limit stays at the 2026 figure. Actual limits are adjusted over time and individual facts vary.
| Beneficiary age | Account age | Eligible to roll? | Amount rolled that year | Cumulative toward $35,000 |
|---|---|---|---|---|
| Birth to 14 | 0 to 14 years | No (15-year rule not met) | $0 | $0 |
| 15 | 15 years | Yes | $7,500 | $7,500 |
| 16 | 16 years | Yes | $7,500 | $15,000 |
| 17 | 17 years | Yes | $7,500 | $22,500 |
| 18 | 18 years | Yes | $7,500 | $30,000 |
| 19 | 19 years | Yes | $5,000 (remaining room) | $35,000 (cap reached) |
Hypothetical illustration only. It assumes sufficient earned income, no other IRA contributions, and a constant $7,500 annual limit; it does not account for the 5-year lookback on specific contributions or state treatment. (Source: savingforcollege.com; 529plancalculator, 2026)
529 to Roth IRA rollover example: a dollar-by-dollar walkthrough
Here is a hypothetical 529 to Roth IRA rollover example. Maya’s parents opened her 529 in 2010; by 2026 it is 16 years old with $40,000 left after college, all contributed before 2021. Maya, age 24, earns $30,000 and makes no other IRA contributions. She can roll $7,500 in 2026, then repeat in later years, reaching the $35,000 lifetime cap in about five years. (Source: SECURE 2.0 Sec. 126; savingforcollege.com, 2026)
Walking through Maya’s numbers year by year (a hypothetical illustration, not a projection):
- Setup. The 529 was opened in 2010, so the 15-year account test is met. All remaining contributions were made before 2021, so they clear the 5-year lookback. Maya is the beneficiary, she has $30,000 of earned income, and the Roth IRA is opened in her name.
- Year 1 (2026). Annual limit $7,500, minus $0 of other IRA contributions, and well under her $30,000 earned income. She rolls $7,500. Cumulative: $7,500.
- Year 2. She rolls another $7,500. Cumulative: $15,000.
- Year 3. She rolls another $7,500. Cumulative: $22,500.
- Year 4. She rolls another $7,500. Cumulative: $30,000.
- Year 5. Only $5,000 of lifetime room remains, so she rolls $5,000 and stops. Cumulative: $35,000, the lifetime cap.
After five years, $35,000 has moved into Maya’s Roth IRA free of federal income tax and the 10% penalty. Any 529 balance above $35,000 stays in the 529 for another qualified use or a different beneficiary; it cannot be rolled to a Roth under the lifetime cap. If Maya had contributed to her own Roth in any of those years, each year’s rollover would have been reduced dollar-for-dollar by that contribution, stretching the timeline.
Can you do a 529 to Roth IRA rollover with a high income?
Generally yes. The Roth IRA MAGI income phase-outs ($153,000 to $168,000 for single filers and $242,000 to $252,000 for joint filers in 2026) are widely understood not to apply to 529 to Roth IRA rollovers, pending final IRS guidance. So a high earner who is otherwise phased out of ordinary Roth contributions can still receive these rollovers. (Source: UBS; Empower; savingforcollege.com, 2026)
This is the feature that draws higher earners: the rollover appears to bypass the income phase-outs that block a normal Roth contribution. The dominant industry reading of the statute is that the MAGI limits simply do not gate these rollovers. (Source: UBS; Empower, 2026) That said, the statute is silent on the point and the IRS has not published final regulations confirming it, so this is best treated as the settled consensus rather than black-letter certainty. The open-questions section below covers the reporting friction that can arise.
Does changing the 529 beneficiary reset the 15-year clock?
Probably, but the IRS has not settled it. Most commentators read Section 126 to mean that changing the 529 beneficiary likely restarts the 15-year account-age requirement, yet no definitive IRS guidance confirms this. A cautious approach keeps the same beneficiary for the full 15 years rather than relying on an unconfirmed reading. (Source: Kitces; savingforcollege.com, 2026)
This is one of the most searched open questions about the rule, and it matters because a wrong assumption can invalidate a rollover. Families who switch a 529 from one child to another should not assume the older account’s history carries over for the new beneficiary. Until the IRS issues final regulations, the conservative planning posture is to treat a beneficiary change as potentially resetting the clock. This is one of several unsettled points covered in the open-questions section further down.
Interactive 529 to Roth eligibility and amount checker
This educational tool estimates whether a 529 to Roth IRA rollover is available and how much could move this year based on the 2026 rules: the 15-year account test, earned income, other IRA contributions, and the $35,000 lifetime cap. It is a general estimate, not tax advice. (Source: SECURE 2.0 Sec. 126; savingforcollege.com, 2026)
Educational estimate only, based on 2026 figures. It does not check the 5-year lookback on specific contributions or your state’s treatment. Not tax or investment advice.
Will your state tax a 529 to Roth IRA rollover?
Federally the rollover is tax-free, but state treatment varies. About ten states may recapture a prior 529 deduction or credit when funds leave for a Roth, and California treats the rollover as a non-qualified withdrawal subject to state tax on earnings plus its 2.5% additional tax. Most other states and no-income-tax states follow federal rules and treat the rollover as tax-free. (Source: instead.com; savingforcollege.com, 2026)
The rollover is tax-free and penalty-free at the federal level, but state conformity is uneven and still evolving. Two patterns create exposure: states that “recapture” a deduction or credit you previously claimed on 529 contributions, and California, which does not conform and treats the move as a non-qualified distribution. Checking your own state’s current rules before acting is important, because guidance keeps shifting. Our discussion of state taxes and Roth conversions covers the broader state-conformity issue.
| State | Treatment of a 529-to-Roth rollover |
|---|---|
| Illinois | May recapture a previously claimed state 529 deduction |
| Indiana | May recapture a previously claimed state 529 credit |
| Iowa | May recapture a previously claimed state 529 deduction |
| Massachusetts | May recapture a previously claimed state 529 deduction |
| Michigan | May recapture a previously claimed state 529 deduction |
| Minnesota | May recapture a previously claimed state 529 deduction or credit |
| Montana | May recapture a previously claimed state 529 deduction |
| New York | May recapture a previously claimed state 529 deduction |
| Utah | May recapture a previously claimed state 529 credit |
| Vermont | May recapture a previously claimed state 529 credit |
| California | Non-conforming: treats the rollover as a non-qualified withdrawal, taxing earnings plus an additional 2.5% state tax |
| Most other income-tax states | Generally follow federal law and treat the rollover as tax-free |
| No-income-tax states (e.g., FL, TX, WA) | No state income tax consequence |
State rules on 529-to-Roth rollovers are still developing; confirm current treatment with your state agency or a tax professional. (Source: instead.com; savingforcollege.com, 2026)
How do you report a 529 to Roth IRA rollover on your taxes?
The 529 plan issues Form 1099-Q for the distribution used in the rollover. The beneficiary reports the 529 to Roth IRA rollover on their own federal return following the IRS instructions for that tax year, and the amount is treated as a Roth contribution for the year. Keep records of the account-open date and prior rollovers to document the 15-year rule and the $35,000 lifetime cap. (Source: savingforcollege.com; Fidelity, 2026)
Because the rollover shows up on Form 1099-Q, tax software or a custodian may occasionally flag it, especially for a high-MAGI beneficiary, since the statute’s MAGI treatment is not yet confirmed in final regulations. Retaining documentation (the plan’s open date, which contributions cleared the 5-year lookback, earned-income records, and a running total of prior rollovers) makes it straightforward to substantiate the reporting if questioned.
How do you roll over a 529 to a Roth IRA?
A 529 to Roth IRA rollover must be a direct trustee-to-trustee transfer: the 529 plan sends funds straight to the beneficiary’s Roth IRA custodian. You cannot take a check and redeposit it. Confirm the 15-year and 5-year tests, open the beneficiary’s Roth, request the direct transfer up to the annual limit, and keep the Form 1099-Q for tax reporting. (Source: savingforcollege.com; Fidelity, 2026)
- Confirm the 529 has been open at least 15 years and identify which contributions are past the 5-year lookback.
- Verify the beneficiary has earned income for the year at least equal to the amount you plan to move.
- Open (or confirm) a Roth IRA in the beneficiary’s name; for a minor with earned income, a custodial Roth may be used.
- Request a direct trustee-to-trustee transfer from the 529 administrator to the Roth custodian, up to the annual limit and net of the beneficiary’s other IRA contributions.
- Keep the Form 1099-Q the 529 plan issues, and report the rollover on the beneficiary’s return following IRS instructions for that year.
- Repeat in later years to work toward the $35,000 lifetime cap, checking state treatment each time.
Taking a distribution to yourself first breaks the rules. If a check goes to the account owner or beneficiary rather than moving directly custodian-to-custodian, the earnings can become taxable and hit the 10% penalty as a non-qualified withdrawal. Sequencing questions like this often overlap with broader planning, including required minimum distributions in 2026 for older account owners.
Common 529 to Roth IRA rollover mistakes to avoid
The most common 529 to Roth IRA rollover mistakes are: taking a check instead of a direct trustee-to-trustee transfer; sending funds to the account owner’s Roth instead of the beneficiary’s; trying to roll the full $35,000 in one year; ignoring the 5-year lookback on recent contributions; overlooking the earned-income requirement; and missing a state recapture or California’s non-conforming tax. Each can trigger tax or penalties. (Source: savingforcollege.com; Kitces, 2026)
- Taking a check first. Any distribution that passes through the owner or beneficiary before landing in the Roth can be recharacterized as a non-qualified withdrawal, taxing the earnings and adding the 10% penalty. A direct trustee-to-trustee transfer is required.
- Wrong Roth owner. Routing the money into the parent’s or grandparent’s Roth instead of the beneficiary’s is not allowed. The Roth must belong to the 529 beneficiary.
- Assuming the $35,000 moves at once. The annual cap ($7,500 in 2026, or $8,600 at 50 and older) means it takes several years. Planning for a lump sum leads to an over-limit request that gets rejected or flagged.
- Forgetting the 5-year lookback. Recent contributions and their earnings are ineligible even when the account itself is 15 years old. Only seasoned funds are eligible to roll.
- No earned income. If the beneficiary has no compensation for the year, no rollover is available, regardless of the balance.
- Overlooking state treatment. A recapture state may claw back a prior deduction or credit, and California taxes the rollover as a non-qualified withdrawal. State treatment should be confirmed each year before funds move.
- Assuming a beneficiary change carries the clock. Switching beneficiaries may reset the 15-year requirement, so do not rely on an older account’s history for a new beneficiary without confirming.
Open questions the IRS hasn’t answered
Several parts of the 529 to Roth rule remain unsettled as of mid-2026. The IRS has not issued final regulations on whether a beneficiary change resets the 15-year clock, exactly how the 5-year lookback treats earnings, or how the MAGI-exemption reading holds up in practice. Treat these as open, not decided. (Source: Kitces; savingforcollege.com, 2026)
Does a beneficiary change reset the 15-year clock? Most commentators assume yes, that switching the beneficiary likely restarts the count, but the IRS has not confirmed this in final guidance. A conservative approach keeps the same beneficiary for the full 15 years rather than relying on an unsettled reading. (Source: Kitces, 2026)
How does the 5-year lookback treat earnings? The statute leaves ambiguity about whether the lookback covers only recent contributions or contributions plus their earnings, and how that interacts with the 15-year rule in edge cases. This awaits IRS clarification.
Does the MAGI exemption always hold? The consensus is that Roth income limits do not apply, but because the statute is silent, some custodians or tax software have flagged high-MAGI rollovers as excess contributions. Until final regulations arrive, the practical answer is “generally not, pending guidance.”
Who bears the cost if a rollover is later disallowed? Because a botched transfer can be recharacterized as a non-qualified withdrawal, the tax and 10% penalty on earnings would fall on the party who received the distribution. Careful documentation reduces that risk.
Work with Q3 Advisors
Q3 Advisors is a registered investment adviser focused on retirement tax planning. This article is educational and is not advice; for guidance on your own circumstances, consult a qualified tax or financial professional.
Frequently asked questions
Can I roll over a 529 to my own Roth IRA if I’m the account owner?
No. The receiving Roth IRA must belong to the 529 beneficiary, not the account owner. A parent or grandparent who owns the 529 cannot direct the money into their own Roth. If your child is the beneficiary, the rollover goes into a Roth IRA in the child’s name, provided the child has enough earned income. (Source: SECURE 2.0 Sec. 126; Fidelity, 2026)
Can I roll over the entire $35,000 in a single year?
No. Each year’s rollover is capped at that year’s IRA contribution limit ($7,500 under 50, or $8,600 at 50 and older in 2026), reduced by the beneficiary’s other IRA contributions and never above their earned income. At $7,500 a year it takes at least five years to reach the $35,000 lifetime cap. (Source: savingforcollege.com, 2026)
Does the 5-year rule apply to the account or to each individual contribution?
To each contribution. The 5-year lookback is separate from the 15-year account-age test. Any contribution made in the last five years, plus its earnings, is ineligible to roll, even if the account itself is well over 15 years old. Only funds that have seasoned at least five years can move. (Source: savingforcollege.com; Empower, 2026)
Does changing the 529 beneficiary reset the 15-year clock?
Probably, but it is not settled. Most commentators read the statute to mean a beneficiary change likely restarts the 15-year account-age requirement, yet the IRS has issued no definitive guidance. A cautious path keeps the same beneficiary for the full 15 years rather than relying on an unconfirmed interpretation. (Source: Kitces; savingforcollege.com, 2026)
Do 529-to-Roth rollovers count toward the annual Roth IRA contribution limit?
Yes. A 529 to Roth rollover uses the beneficiary’s own IRA contribution room for that year. In 2026 the ceiling is $7,500 (under 50) or $8,600 (50 and older), reduced by any other traditional or Roth IRA contributions the beneficiary makes. Rollover plus direct contributions cannot exceed that annual limit. (Source: SECURE 2.0 Sec. 126; savingforcollege.com, 2026)
Can I roll over 529 funds to a Roth IRA if I have a high income?
Generally yes. The Roth MAGI phase-outs ($153,000 to $168,000 single, $242,000 to $252,000 joint in 2026) are widely understood not to apply to 529 to Roth rollovers, so a high earner locked out of ordinary Roth contributions can still receive one. Final IRS regulations have not confirmed this, so treat it as strong consensus. (Source: UBS; Empower, 2026)
Does the beneficiary need earned income to do a 529 to Roth rollover?
Yes. The beneficiary must have earned (compensation) income for the year at least equal to the amount rolled. If they earn $4,000, only $4,000 can move that year even though the annual ceiling is higher. With no earned income, no rollover is available that year, though a summer or part-time job can create room. (Source: SECURE 2.0 Sec. 126; Empower, 2026)
Will my state tax or recapture deductions on a 529 to Roth IRA rollover?
Possibly. About ten states may recapture a 529 deduction or credit you previously claimed when funds leave for a Roth, and California treats the rollover as a non-qualified withdrawal subject to state tax on earnings plus a 2.5% additional tax. Most other income-tax states and no-income-tax states follow federal rules. Check your state each year. (Source: instead.com; savingforcollege.com, 2026)
Can I withdraw 529 funds and then contribute them to a Roth IRA instead?
No. The move must be a direct trustee-to-trustee transfer from the 529 plan to the Roth IRA custodian. Taking a distribution to yourself first, then contributing, breaks the rule and can make the earnings taxable plus subject to the 10% non-qualified withdrawal penalty. The money must move directly between institutions. (Source: savingforcollege.com; Fidelity, 2026)
How do I report a 529 to Roth IRA rollover on my tax return?
The 529 plan issues Form 1099-Q for the distribution used in the rollover. The beneficiary reports it on their federal return following the IRS instructions for that tax year, and it is treated as a Roth contribution for the year. Keep records of account-open dates and prior rollovers to document the $35,000 lifetime cap. (Source: savingforcollege.com, 2026)
Is there an age limit for 529 to Roth IRA rollovers?
No. Unlike a Coverdell education savings account, a 529 plan has no age limit for the beneficiary and funds are not forced out at age 30. That flexibility is part of why leftover 529 money can sit until the 15-year and 5-year tests are met and then roll to a Roth IRA for the same beneficiary. (Source: savingforcollege.com, 2026)
Sources
SECURE 2.0 Act of 2022, Section 126 (statutory text on 529-to-Roth rollovers).
Fidelity, 529-to-Roth IRA rollover guidance (2026).
savingforcollege.com, 529 to Roth IRA rollover rules (2026).
Empower, 529-to-Roth rollover overview (2026).
UBS, high-earner Roth access via 529 rollovers (2026).
Kitces, analysis of SECURE 2.0 Section 126 open questions (2026).
529plancalculator, 529-to-Roth rollover timeline (2026).
instead.com, state tax treatment of 529-to-Roth rollovers (2026).
IRS, general 529 and Roth IRA rules; note the IRS has not issued final regulations on Section 126 as of July 2026.
