A QCD from a 401k is not allowed directly, because a qualified charitable distribution can come only from an IRA, so roll 401(k) funds into a traditional IRA first, then make the QCD from that IRA.
Key Takeaways
- Under IRC section 408(d)(8), a QCD must move directly from an IRA trustee, so 401(k), 403(b), 457(b), and TSP plans cannot originate one.
- For 2026, each eligible person can exclude up to $111,000 of QCDs from gross income, up from $108,000 in 2025.
- A married couple with separate IRAs can reach $222,000 combined in 2026 QCDs.
- The donor must be at least 70½ on the distribution date, while RMDs do not start until age 73 (age 75 for those born in 1960 or later, first affecting 2035).
- A direct rollover avoids the 20% withholding and 60-day risk of an indirect rollover, and transfers commonly take one to two weeks.
- The SECURE 2.0 one-time split-interest election is $55,000 for 2026 and counts inside the annual QCD limit, not on top of it.
- Most retirees take the 2026 standard deduction ($16,100 single, $32,200 married filing jointly), so a QCD can lower AGI without itemizing.
QCD 2026 figures at a glance
Figures are for 2026 and drawn from the cited IRS sources. QCD eligibility begins at 70½, while required minimum distributions start at age 73.
A QCD from a 401k is not allowed directly. A qualified charitable distribution can be made only from an IRA, so money cannot move straight from a 401(k) to charity as a QCD. The practical fix is a direct rollover of 401(k) funds into a traditional IRA, then a QCD from that IRA under the standard rules.
No, a QCD cannot be made directly from a 401(k). Under IRC section 408(d)(8), a qualified charitable distribution is a transfer made directly by the trustee of an IRA to a qualified charity, so 401(k), 403(b), 457(b), and TSP plans are excluded. To use 401(k) money, roll it to a traditional IRA first, then make the QCD (Source: IRS Publication 590-B, 2025).
The QCD provision attaches to IRAs, not to workplace plans, so this guide covers the rollover workaround, the 2026 limits, the age 70½ timing quirk, the current-year RMD trap, and how a QCD interacts with your RMD, Medicare, and Social Security.
Why you cannot make a QCD directly from a 401(k)
A QCD cannot come directly from a 401(k) because IRC section 408(d)(8) defines a qualified charitable distribution as a transfer made by the trustee of an IRA. The statute names the IRA, so employer plans (401(k), 403(b), 457(b), and the federal Thrift Savings Plan) are excluded as QCD sources, regardless of the pre-tax dollars inside them (Source: IRS Publication 590-B, 2025).
The reason is statutory: Congress tied the exclusion to distributions from an individual retirement account, and a 401(k) is a qualified employer plan under a separate part of the code. Active SEP or SIMPLE IRAs that received an employer contribution for the year are also ineligible until inactive (Source: IRS Publication 590-B, 2025).
The workaround: roll the 401(k) to an IRA, then make the QCD
Because a QCD from a 401k is blocked at the source, the standard route is a direct (trustee-to-trustee) rollover of 401(k) funds into a traditional IRA, followed by a QCD from that IRA. The rollover itself is not a taxable event, because pre-tax dollars change account type. Once the money sits in the IRA, every standard QCD rule applies (Source: IRS Publication 590-B, 2025).
A direct rollover sends the money straight to the receiving IRA custodian, avoiding the 20% withholding and 60-day risk of an indirect rollover. The steps:
- Confirm a traditional IRA as the destination; a Roth IRA would make the rollover a taxable conversion.
- Request a direct rollover: the 401(k) administrator sends funds trustee-to-trustee to the IRA custodian, with no check to you.
- Wait for the balance to appear in the IRA; transfers commonly take one to two weeks.
- Instruct the custodian to pay the 501(c)(3) directly, giving the charity’s legal name, address, and amount; a check issued to you is not a QCD.
- Keep the custodian confirmation and the charity’s written acknowledgment that no goods or services were provided.
If you also expect to convert part of your balance to Roth, coordinate the sequence with our Roth conversion planning overview and the guide on how much to convert to Roth.
Which accounts and charities qualify for a QCD
QCDs originate only from IRAs: traditional, rollover, inherited, and inactive SEP or SIMPLE IRAs. Employer plans such as 401(k), 403(b), 457(b), and the TSP do not qualify. The money must go to a qualified 501(c)(3) public charity, not a donor-advised fund, private foundation, or supporting organization (Source: IRS Publication 590-B, 2025).
| Account type | Can it originate a QCD? | Notes |
|---|---|---|
| Traditional IRA | Yes | The primary QCD source. |
| Rollover IRA (from a 401k) | Yes | Destination for rolled 401(k) money. |
| Inherited IRA | Yes | Beneficiary must be 70½ on the distribution date. |
| Inactive SEP or SIMPLE IRA | Yes | No employer contribution for the current year. |
| Roth IRA | Technically yes | Rarely useful; Roth withdrawals are generally already tax-free. |
| 401(k) | No | Roll to a traditional IRA first. |
| 403(b), 457(b), TSP | No | Employer plans are excluded. |
| Active SEP or SIMPLE IRA | No | Disqualified while receiving employer contributions. |
Excluded as QCD recipients: donor-advised funds, private foundations (certain private operating foundations may qualify), and 509(a)(3) supporting organizations. The destination should be a 501(c)(3) public charity under IRC section 170(b)(1)(A) (Source: IRS Publication 590-B, 2025).
QCD rules and 2026 limits
For 2026, each eligible person can exclude up to $111,000 of QCDs from gross income, so a married couple with separate IRAs can reach $222,000 combined (Source: IRS Notice 2025-67). The donor must be at least 70½ on the distribution date, the funds must move directly from the IRA custodian to a qualified 501(c)(3), and no goods or services may be received in return.
The age test looks at the actual distribution date, not just the year you turn 70½, and the $111,000 limit is indexed for inflation (up from $108,000 in 2025). The full 2026 figures:
| QCD feature (2026) | Figure |
|---|---|
| Minimum age | 70½ on the distribution date |
| Annual exclusion per person | $111,000 |
| Combined for a married couple (separate IRAs) | $222,000 |
| One-time split-interest election (CGA or CRT) | $55,000 |
The current-year 401(k) RMD trap
If a 401(k) required minimum distribution is already due for the year, rolling the 401(k) to an IRA does not satisfy it. An RMD is not an eligible rollover distribution, so the 401(k) RMD must be paid out as taxable income first, before the remaining balance moves to the IRA. That RMD amount cannot be turned into a QCD (Source: IRS Publication 590-B, 2025; IRS RMD FAQs).
This trap catches people who wait until they are already subject to RMDs. Moving 401(k) funds to an IRA before RMDs begin, ideally between 70½ and 73, keeps every dollar available for a QCD. See our guide to required minimum distributions for 2026.
The age 70½ vs 73 timing gap and the first-dollars-out rule
QCD eligibility begins at 70½, but required minimum distributions do not start until age 73 (age 75 for those born in 1960 or later, first affecting 2035). That gap lets a person make QCDs for roughly two and a half years before any RMD is due, gradually reducing the IRA balance and the future RMD it drives (Source: IRS RMD FAQs; SECURE 2.0 Act Section 107).
Someone who rolls a 401(k) into a traditional IRA at 70 can begin QCDs at 70½, before the first RMD at 73, and each QCD lowers the balance that later drives the RMD. Once RMDs begin, ordering matters: the first dollars out of the IRA satisfy the RMD, so a QCD must happen before any other distribution to count toward it. Take an ordinary distribution first, and it uses up the RMD.
How a QCD lowers your taxable income
A QCD is excluded from gross income rather than claimed as a deduction, so it lowers adjusted gross income without itemizing, and it can satisfy that year’s RMD. Because many items key off AGI, a QCD can influence the taxable share of Social Security benefits and the income thresholds behind Medicare IRMAA surcharges (Source: IRS Publication 590-B, 2025).
Taking an RMD and then donating is the contrast: that withdrawal is ordinary income, and the offsetting deduction helps only if you itemize. Most retirees take the 2026 standard deduction ($16,100 single, $32,200 married filing jointly), so a QCD keeps AGI lower either way. Three AGI-linked areas often matter:
- Social Security taxation. Up to 85% of benefits can be taxable depending on combined income, which a QCD can hold down.
- Medicare IRMAA. Part B and Part D surcharges begin above $109,000 (single) and $218,000 (joint) in modified AGI; a QCD does not add to that income.
- Net investment income tax. The 3.8% net investment income tax applies above $200,000 (single) and $250,000 (joint) MAGI, so households often pair QCDs with partial Roth conversions to shape income.
The one-time $55,000 split-interest election
The SECURE 2.0 Act added a once-in-a-lifetime election to direct a QCD to a split-interest entity such as a charitable gift annuity or charitable remainder trust. For 2026 this one-time amount is $55,000 and counts inside the annual QCD limit, not on top of it (Source: IRS Notice 2025-67).
The receiving vehicle must meet the statutory requirements for a charitable gift annuity or remainder trust. For most donors giving to operating charities the standard QCD is simpler; the split-interest election suits those who want an income stream back.
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Q3 Advisors is a registered investment adviser focused on retirement tax planning. This page is educational and is not advice; consult a qualified professional.
Frequently asked questions
Can you make a QCD directly from a 401(k)?
No. Under IRC section 408(d)(8), a qualified charitable distribution must move directly from an IRA trustee to a charity, so a 401(k) cannot originate one. The fix is to roll 401(k) funds into a traditional IRA, then make the QCD from that IRA under the standard rules (Source: IRS Publication 590-B, 2025).
Can you donate your 401(k) RMD to charity?
You can withdraw a 401(k) RMD and give it away, but that withdrawal is taxable income and it is not a QCD; a 401(k) RMD cannot be rolled over or converted into one. Roll pre-RMD balances to a traditional IRA first, then make QCDs (Source: IRS Publication 590-B, 2025).
Can I roll my 401(k) into an IRA and then do a QCD?
Yes. A direct trustee-to-trustee rollover moves pre-tax 401(k) dollars into a traditional IRA tax-free, and the IRA can then originate a QCD. If a current-year 401(k) RMD is due, take it first, because an RMD cannot be rolled over (Source: IRS Publication 590-B, 2025).
What accounts are eligible for a qualified charitable distribution?
QCDs originate only from IRAs: traditional, rollover, inherited, and inactive SEP or SIMPLE IRAs. Active SEP or SIMPLE IRAs, 401(k)s, 403(b)s, 457(b)s, and the federal TSP cannot. Roth IRAs technically allow QCDs but rarely benefit, since Roth distributions are usually already tax-free (Source: IRS Publication 590-B, 2025).
What is the QCD limit for 2026?
For 2026, each eligible person can exclude up to $111,000 of QCDs from gross income, up from $108,000 in 2025. Two spouses with separate IRAs can reach $222,000 combined. A once-in-a-lifetime split-interest election of up to $55,000 counts inside that annual limit (Source: IRS Notice 2025-67).
At what age can you make a qualified charitable distribution?
The donor must be at least 70½ on the actual distribution date, not merely in the year they turn 70½. That is earlier than the age 73 RMD start date, so QCDs can begin roughly two and a half years before RMDs are required (Source: IRS Publication 590-B, 2025; IRS RMD FAQs).
Does a QCD count toward your RMD?
Yes. A QCD from an IRA can satisfy all or part of that year’s required minimum distribution while staying out of taxable income. Because the first dollars out of the IRA count toward the RMD, make the QCD before any other distribution from that IRA (Source: IRS Publication 590-B, 2025).
Can a QCD go to a donor-advised fund?
No. Donor-advised funds are excluded as QCD recipients, along with private foundations and 509(a)(3) supporting organizations. A QCD must go to a qualified 501(c)(3) public charity. The narrow exception is a one-time split-interest election to a charitable gift annuity or remainder trust (Source: IRS Publication 590-B, 2025).
Sources
IRS Publication 590-B (2025). | IRS Notice 2025-67 (2026 COLA; QCD limit $111,000; split-interest amount $55,000). | IRS Retirement Plan and IRA RMD FAQs (SECURE 2.0 Section 107; RMD age 73, and 75 for those born in 1960 or later). | Internal Revenue Code section 408(d)(8).
