A Roth conversion before RMDs means moving money from a traditional IRA or 401(k) into a Roth account during the low-income years after you stop working but before required minimum distributions begin. Under SECURE 2.0, that window now stretches to age 73 or 75, giving many retirees five to twelve extra years to convert at what remain some of the lowest tax rates in over fifty years.
The Roth conversion window before RMDs is the stretch of low-taxable-income years between the end of your paycheck and the start of required minimum distributions at age 73 (born 1951 to 1959) or 75 (born 1960 or later). Converting during these gap years fills lower brackets, reduces future RMDs, and can limit Medicare IRMAA surcharges. A conversion is uncapped, taxed as ordinary income, and irreversible.
What is the Roth conversion window before RMDs?
The Roth conversion window before RMDs is the set of years after you retire but before required minimum distributions begin, usually five to twelve years long. During this gap your taxable income often drops sharply, so converting traditional IRA or 401(k) dollars to Roth is taxed in lower brackets. The IRS treats each conversion as ordinary income in the year you make it.
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For a couple who retires at 62 and reaches RMD age at 73, that is eleven open years. Wages have stopped, but Social Security and pensions may be deferred, so reported income can sit far below where it was during peak earning years. Those years are the planning space this page is about, and deciding how much to move each year is its own question we cover in how much to convert to Roth.
A conversion is different from a contribution. Roth contributions phase out at $153,000 to $168,000 of income for single filers and $242,000 to $252,000 for joint filers in 2026, and are capped at $7,500 (or $8,600 if you are 50 or older). A conversion has no income limit and no dollar cap. You can convert $20,000 or $200,000 in a year, and you owe ordinary income tax on the pre-tax amount you move.
Why did the SECURE Act give you a bigger window?
The SECURE Act of 2019 and SECURE 2.0 (2022) pushed the RMD start age from 70.5 up to 73, and then to 75 for younger savers. Each delay adds conversion runway: years you can move money to Roth before the IRS forces taxable withdrawals. Many retirees read the change only as a tax break, but the deferred start date is really extra planning space.
The original page you may have read here was written when the House first passed the 2019 bill and RMDs still started at 70.5. Both laws are now settled. The practical result is that the IRS no longer forces distributions as early, so the low-income runway before mandatory withdrawals is wider than it was for the prior generation of retirees.
When do RMDs actually start now, age 73 or 75?
Under SECURE 2.0, required minimum distributions start at age 73 if you were born from 1951 to 1959, and at age 75 if you were born in 1960 or later. The earliest anyone reaches the age-75 rule is calendar year 2035. Original Roth IRA owners have no lifetime RMDs at all, and Roth 401(k)s became exempt from RMDs starting in 2024.
| Birth year | RMD start age | First RMD year |
|---|---|---|
| 1950 or earlier | 72 (prior rule) | Already begun |
| 1951 to 1959 | 73 | 2024 to 2032 |
| 1960 or later | 75 | 2035 or later |
The mechanics of each year’s mandatory withdrawal, including how the IRS uniform table sets the amount, sit in our companion reference on required minimum distributions in 2026. For the tighter rules on how conversions and RMDs interact once you cross the start age, see our sibling article, critical insights on Roth conversions and RMDs.
Why are the gap years your cheapest years to convert?
Gap years are often your cheapest conversion years because Social Security, pensions, and RMDs have not switched on yet, leaving room in the 10%, 12%, and 22% brackets. In 2026 the 22% bracket for a married couple filing jointly runs from $100,800, and the 24% bracket reaches $403,550 before 32% begins. Federal rates today sit near their lowest in over fifty years.
| 2026 rate | Bracket begins (single) | Bracket begins (married filing jointly) |
|---|---|---|
| 22% | $50,400 | $100,800 |
| 24% | up to $201,775 | up to $403,550 |
| 32% | $201,775 | $403,550 |
| 35% | $256,225 | $512,450 |
| 37% | $640,600 | $768,700 |
The 2026 standard deduction is $16,100 for single filers and $32,200 for a married couple filing jointly, plus $1,650 per spouse who is 65 or older. A retired couple both over 65 can therefore report roughly the first $35,500 of income tax-free, then work up through the 10% and 12% bands before the 22% bracket even starts. That headroom is what a conversion fills.
Rates matter because the tax you pay to convert is locked in at today’s schedule. If you expect brackets to rise, converting while rates are low can be worth more than deferring. This is the timing logic behind a Roth conversion break-even analysis, which weighs tax paid now against tax and RMDs avoided later.
How much can waiting really cost you?
Waiting can be expensive. A married couple, both age 60, with a combined $1 million in IRAs and 401(k)s may pay more than $800,000 in income taxes across their lifetimes and legacy if the accounts keep compounding untouched. Larger balances force larger RMDs, which push taxable income higher every year once withdrawals become mandatory at 73 or 75.
There is a second cost that few plans price in: the survivor’s penalty. When one spouse dies, the survivor usually files as single the very next year. The same retirement income that fit comfortably in the joint 22% bracket ($100,800 base in 2026) can meet the single 22% and 24% brackets, which begin at far lower income. A widow or widower can owe more tax on less spending, on top of a full RMD.
Converting during the gap years can shrink the pre-tax balance that drives both problems. A smaller traditional IRA produces a smaller RMD, and Roth dollars the survivor draws later are not taxable at all. Original Roth owners also face no lifetime RMDs, so the money can stay invested rather than being forced out into a compressed single-filer bracket.
Does a Roth conversion count as an RMD?
No. A Roth conversion does not count as, and cannot satisfy, a required minimum distribution. Once you reach RMD age (73 or 75), you must take the full RMD first, and that RMD itself can never be converted to Roth. Only dollars above the RMD amount are eligible to convert, which is one reason converting during the gap years, before RMDs begin, is cleaner.
This ordering trips up people who wait. Say your RMD is $40,000 and you want to convert $30,000 in the same year. You must distribute the $40,000 as taxable income first, then convert the additional $30,000 on top, for $70,000 of taxable income that year. In a gap year with no RMD, the same $30,000 conversion stands alone in a lower bracket.
At what age is it too late to convert?
It is never truly too late to convert, because there is no upper age limit on Roth conversions. But every year you are in RMD mode is bracket space lost, since the mandatory withdrawal fills your lower brackets first and a conversion stacks on top. The IRS also applies a separate five-year clock to each conversion’s earnings, though that clock is waived for withdrawals once you are 59.5 or older.
The five-year rule is widely misread. For anyone 59.5 or older, the converted principal is available immediately with no penalty and no tax, because that tax was already paid at conversion. The five-year clock only affects the earnings portion, and it runs separately for each conversion year. Under 59.5, withdrawing converted principal within five years can trigger the 10% early-distribution penalty.
How to build a year-by-year conversion plan
A year-by-year Roth conversion plan converts just enough each year to fill a target bracket without spilling into the next one or tripping a surcharge. Many retirees convert up to the top of the 22% or 24% bracket, stay under the Medicare IRMAA income thresholds, and pay the resulting tax from non-retirement savings so the entire conversion lands in the Roth.
- Set a bracket ceiling. Pick a top rate you are willing to pay, often 22% or 24%, and convert only up to that line. In 2026 the 24% bracket runs to $403,550 of taxable income for a couple filing jointly.
- Watch the Medicare IRMAA cliffs. Higher-income premiums begin above $109,000 of modified adjusted gross income for single filers and $218,000 for joint filers, using a two-year lookback. The standard 2026 Part B premium is $202.90 per month. Because of the lookback, age 62 is generally the last conversion year that does not affect a Part B premium at 65.
- Mind the 3.8% surtax. A conversion is ordinary income, not net investment income, so it is not itself hit by the net investment income tax. But a large conversion can raise your MAGI above the $200,000 single or $250,000 joint threshold and pull your actual investment income into the 3.8% surtax. See the net investment income tax in 2026.
- Pay the tax from outside funds. Use taxable brokerage or cash to cover the conversion tax so the full pre-tax amount moves into the Roth and keeps compounding.
- Finish by December 31. A conversion counts for the year the money leaves the traditional account. There is no prior-year grace period, so the deadline is firm, as covered in our note on the Roth conversion deadline for 2026.
Because a conversion is irreversible (the recharacterization option ended in 2018), the sizing decision matters. A structured multi-year approach, reviewed against your other income each year, is what our Roth conversion planning work is built around.
Frequently asked questions
Does a Roth conversion count as an RMD?
No. A Roth conversion cannot count as or satisfy a required minimum distribution. In any year you are RMD age (73 or 75), you must withdraw the full RMD first as taxable income, and that RMD can never be converted to Roth. Only amounts above the RMD are eligible to convert. This is why the gap years, before RMDs start, are the simpler time to convert.
Should you do a Roth conversion before RMDs start?
Many investors find the gap years before RMDs the most efficient time to convert, because taxable income is often lowest then and conversions can fill the 12%, 22%, or 24% brackets. Converting earlier may lower future RMDs and reduce the survivor’s tax burden. Whether it fits depends on your brackets, cash to pay the tax, and time horizon, so a personalized review is worthwhile.
At what age is it too late to do a Roth conversion?
There is no age limit on Roth conversions, so it is never strictly too late. That said, once RMDs begin at 73 or 75, the mandatory withdrawal fills your lower brackets first, leaving less low-rate room for a conversion stacked on top. Many people find the pre-RMD gap years the most cost-effective window. Conversions in later years can still help, just usually at a higher marginal rate.
Do Roth IRAs have RMDs?
Original Roth IRA owners have no required minimum distributions during their lifetime, so the money can stay invested as long as you live. As of 2024, Roth 401(k) accounts are also exempt from lifetime RMDs. Inherited Roth accounts are different: most non-spouse beneficiaries must empty the account within ten years, though qualified Roth withdrawals remain income-tax-free.
Do I have to wait 5 years to access a Roth conversion?
If you are 59.5 or older, no. The converted principal was already taxed, so you can withdraw it anytime without tax or penalty. The five-year rule applies a separate clock to each conversion’s earnings, and for those under 59.5 it can trigger the 10% early-distribution penalty on converted amounts withdrawn too soon. After 59.5, that penalty concern falls away.
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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.
