A QCD from a 401k is not something the tax code permits directly. A qualified charitable distribution from a 401(k) cannot be made, because the QCD provision applies only to IRAs, 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, after which the QCD is made from that IRA.
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, so 401(k), 403(b), 457(b), and TSP plans are excluded. To use 401(k) money, first roll it to a traditional IRA, then make the QCD (Source: IRS Publication 590-B, 2025).
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Many retirees and their heirs look for a way to send 401(k) money straight to a charity and skip the tax. The instinct is reasonable, but the rule is specific: the QCD provision attaches to IRAs, not to workplace plans. This article walks the 401(k)-to-IRA rollover workaround, the 2026 limits, the age-70½ timing quirk, and how a QCD interacts with your RMD, Medicare surcharges, and Social Security taxation.
Why you cannot make a QCD directly from a 401(k)
A QCD is defined in IRC section 408(d)(8) as a distribution made directly by the trustee of an IRA to a qualified charity. Because the statute names the IRA, employer-sponsored plans do not qualify. The IRS states QCDs are available only from IRAs, which means 401(k), 403(b), 457(b), and TSP accounts are not eligible sources (Source: IRS Publication 590-B, 2025).
The reason is statutory rather than economic. Congress tied the exclusion to distributions from an individual retirement account. A 401(k) is a qualified employer plan governed by a separate part of the code, so its distributions do not receive QCD treatment even though the underlying dollars are pre-tax in the same way IRA dollars are. The accounts that cannot originate a QCD include 401(k), 403(b), and 457(b) plans, the federal Thrift Savings Plan, and active SEP or SIMPLE IRAs that received an employer contribution for the year (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 simply change account type. Once the money sits in the IRA, all standard QCD rules apply.
A direct rollover means the plan sends the money straight to the receiving IRA custodian; the check is not written to you. That distinction matters because an indirect (60-day) rollover can trigger mandatory 20% withholding and the risk of missing the deadline. The direct route:
- Open or identify a traditional IRA. Confirm the receiving account is a traditional IRA (a Roth IRA would make the rollover a taxable conversion).
- Request a direct rollover from the 401(k). Ask the plan administrator to send the funds trustee-to-trustee to the IRA custodian. Provide the receiving account details so no check passes through your hands.
- Confirm the funds have landed. Wait until the balance appears in the IRA before doing anything else. Transfers commonly take one to two weeks.
- Instruct the IRA custodian to make the QCD. Give the charity’s legal name and address and the amount. The custodian must send the money directly to the 501(c)(3); if a check is issued to you, it is not a QCD.
- Collect documentation. Keep the custodian’s confirmation and a written acknowledgment from the charity stating that no goods or services were provided in exchange.
- Report it correctly. The custodian reports the gross distribution on Form 1099-R. On the return, the gross amount is entered and the QCD portion is noted so it is excluded from taxable income (Source: IRS Publication 590-B, 2025).
If you also plan to convert part of your retirement balance to Roth, coordinate the sequence carefully; our overview of Roth conversion planning and the guide on how much to convert to Roth explain how charitable transfers and conversions can share the same tax year.
Which accounts qualify for a QCD, and which do not
QCDs originate only from IRAs: traditional IRAs, rollover IRAs, inherited IRAs, and inactive SEP or SIMPLE IRAs all qualify. Active SEP and SIMPLE IRAs, 401(k)s, 403(b)s, 457(b)s, and the TSP do not. Roth IRAs technically permit QCDs, though a QCD from a Roth IRA is rarely useful because Roth distributions are generally already tax-free (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 | The workaround destination for 401(k) money. |
| Inherited IRA | Yes | Beneficiary must be at least 70½ on the distribution date. |
| Inactive SEP or SIMPLE IRA | Yes | No employer contribution for the current year. |
| Roth IRA | Technically yes | Rarely advantageous; 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 | Ongoing employer contributions disqualify it for the year. |
| Donor-advised fund (as recipient) | Not eligible recipient | DAFs, private foundations, and supporting orgs cannot receive a QCD. |
Can you make a QCD from an inherited IRA?
Yes, and the age test looks at the beneficiary rather than the original owner: you must have reached 70½ yourself to make the gift, so a younger heir does not yet qualify. A QCD from an inherited IRA still counts toward that account’s required distribution, including the annual RMDs some heirs owe under the 10-year rule. Converting an inherited IRA to a Roth is a separate question with a mostly-no answer for non-spouse beneficiaries — see can you convert an inherited IRA to Roth.
Which charities can receive a QCD (and which cannot)
A QCD can go only to a qualified charity that is a public charity under IRC section 170(b)(1)(A), generally a 501(c)(3) operating charity. Donor-advised funds, private foundations, and supporting organizations are not eligible recipients. The gift must produce no return benefit to the donor (Source: IRS Publication 590-B, 2025).
The eligible source is only half of the rule; the receiving organization matters just as much. The transfer must go directly from the IRA custodian to a charity that would qualify for a charitable deduction, which excludes three common vehicles that otherwise accept gifts. Recipients that cannot receive a QCD include:
- Donor-advised funds. A DAF is a popular giving account, but it is specifically excluded as a QCD recipient. Money for a DAF must come from taxable dollars, not a QCD.
- Private foundations. A family or private non-operating foundation does not qualify, though certain private operating foundations may.
- Supporting organizations. A 509(a)(3) supporting organization is excluded even though it is technically a public charity.
The narrow exception is the one-time split-interest election covered below, which allows a QCD to fund a charitable gift annuity or charitable remainder trust. For an ordinary gift, the destination should be a 501(c)(3) public charity, and the donor should obtain a written acknowledgment confirming no goods or services were received in exchange (Source: IRS Publication 590-B, 2025).
QCD limits for 2026: individual vs. married filing jointly
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 core requirements once the money is inside an IRA:
- Age. At least 70½ on the day of the distribution, not merely the year you turn 70½ (Source: IRS Publication 590-B, 2025).
- 2026 annual limit. $111,000 per person, indexed for inflation, up from $108,000 in 2025 (Source: IRS Notice 2025-67).
- Direct transfer. The check must never touch the donor; it goes from custodian to charity.
- Eligible recipient. A 501(c)(3) public charity. Donor-advised funds, private foundations, and supporting organizations do not qualify.
- No return benefit. The donor cannot receive goods, services, or a ticket in exchange.
| QCD feature | 2026 figure |
|---|---|
| Minimum age | 70½ on the distribution date |
| Annual exclusion per person | $111,000 |
| Combined for married couple (separate IRAs) | $222,000 |
| One-time split-interest election (CGA/CRT/CRUT) | $55,000 |
| Eligible source accounts | Traditional, rollover, inherited, inactive SEP/SIMPLE IRA |
| Ineligible source accounts | 401(k), 403(b), 457(b), TSP, active SEP/SIMPLE |
Figures for 2026 from IRS Notice 2025-67 (annual COLA amounts) and IRS Publication 590-B (2025).
The age 70½ vs age 73 timing gap
QCD eligibility begins at 70½, but required minimum distributions do not start until age 73 (age 75 for those reaching 74 after 2032). That gap means a person can 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).
This mismatch is where the planning value sits. Someone who rolls a 401(k) into a traditional IRA at age 70 can begin QCDs at 70½, before the first RMD at 73. Each QCD lowers the IRA balance, which lowers the RMD that balance will later require. Waiting until RMDs begin is not a mistake, but the early window exists and is often overlooked.
There is also a 401(k)-specific wrinkle. The “still-working exception” lets a participant delay RMDs from a current employer’s 401(k) until the year they retire, provided they are not a 5% owner of the business. That exception does not apply to IRAs, so once 401(k) money is rolled to an IRA it becomes subject to IRA RMD timing at 73 (Source: IRS Retirement Plan and IRA RMD FAQs). For more, see our guide to required minimum distributions for 2026.
The “first dollars out” rule once money is in the IRA
In a year when an RMD is due, the first dollars distributed from the IRA are treated as satisfying the RMD. To have a QCD count toward the RMD, the QCD generally needs to happen before any other distribution from that IRA for the year. If an ordinary distribution is taken first, it uses up the RMD and a later QCD, while still excluded from income, no longer offsets a taxable RMD.
Why the 401(k)-to-IRA rollover will not satisfy your current-year 401(k) RMD
If a 401(k) RMD is already due for the year, rolling the 401(k) to an IRA does not satisfy it. An RMD cannot be rolled over, so the 401(k) RMD must be taken from the 401(k) first, as taxable income, 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 is the trap that catches people who wait until they are already subject to RMDs before setting up the rollover-then-QCD route. Once RMDs have begun, a required minimum distribution is not an eligible rollover distribution. If the plan owes a 401(k) RMD for the current year, that amount must come out of the 401(k) as an ordinary taxable withdrawal first; only the balance above the RMD can be rolled to the IRA. The 401(k) RMD itself stays in taxable income and cannot be redirected as a QCD, because a QCD can only originate from the IRA once the money is there.
The practical takeaway is timing. Moving 401(k) funds to an IRA before RMDs begin, ideally between 70½ and 73, avoids this problem entirely and lets every eligible dollar be available for a QCD. Rolling over in a year when a 401(k) RMD is already triggered still works, but the current-year 401(k) RMD is a cost that a QCD cannot offset. See our guide to required minimum distributions for 2026 for the applicable-age rules.
How a QCD affects your taxes
A QCD is excluded from gross income rather than claimed as a deduction, so it lowers adjusted gross income without requiring you to itemize. Because many downstream 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).
The contrast with taking a normal RMD and then donating is the point. A withdrawal taken as ordinary income and then given to charity produces a deduction only if you itemize, and most retirees take the standard deduction ($16,100 single, $32,200 married filing jointly for 2026). A QCD skips that step: the income never appears, so AGI stays lower whether or not you itemize. Two AGI-linked areas are commonly relevant:
- Social Security taxation. Up to 85% of benefits can be taxable depending on combined income. Keeping a distribution out of income through a QCD can affect that calculation. Our overview of the taxation of Social Security benefits in 2026 explains the mechanics.
- Medicare IRMAA. Part B and Part D surcharges are set by income, with the first tier beginning above $109,000 (single) and $218,000 (joint). A QCD does not add to the AGI that drives those brackets. See the 2026 Medicare IRMAA brackets and premiums for the tiers.
How to report a QCD from your rolled-over IRA on your tax return
The IRA custodian reports the full distribution on Form 1099-R and does not flag the QCD separately, so the exclusion is self-reported. On Form 1040, the total distribution goes on line 4a, the taxable amount (the total minus the QCD) goes on line 4b, and you write “QCD” next to line 4b (Source: IRS Publication 590-B, 2025).
Because the 1099-R shows the gross amount with no code identifying the charitable portion, the return has to tell the IRS how much to exclude. The steps for a QCD made from the rolled-over IRA:
- Enter the full distribution on Form 1040 line 4a. This is the total amount the custodian reported on the 1099-R, including the QCD.
- Enter the taxable amount on line 4b. Subtract the QCD from the total. If the entire distribution was a QCD, line 4b is zero.
- Write “QCD” beside line 4b. This notation tells the IRS the difference between 4a and 4b is an excluded qualified charitable distribution.
- Keep the acknowledgment. Retain the charity’s written statement that no goods or services were provided, along with the custodian’s confirmation, in case the return is questioned.
No charitable deduction is claimed on Schedule A for the QCD amount, because the money was already excluded from income; deducting it as well would be double counting (Source: IRS Publication 590-B, 2025).
A worked example (hypothetical)
This section walks through a hypothetical retiree to illustrate how the ordering of a QCD and an ordinary distribution can change how much of a required minimum distribution lands in adjusted gross income. The figures are illustrative only, describe no real client, and are not a projection of results. Individual outcomes depend on each person’s income, thresholds, and filing situation (Source: IRS Publication 590-B, 2025).
The following figures are illustrative and describe a hypothetical individual, not a real client and not a projection of results.
Suppose a 74-year-old has a $60,000 RMD due from a traditional IRA that was funded partly by a prior 401(k) rollover, and intends to give $25,000 to a qualified public charity this year. Two paths:
- Path A, QCD first. A $25,000 QCD is made before any other distribution. It counts toward the RMD and is excluded from income. The remaining $35,000 is taken as ordinary income, so only $35,000 of the $60,000 lands in AGI.
- Path B, distribute then donate. The full $60,000 RMD is taken as income, then $25,000 is donated. For a taxpayer using the standard deduction, the gift produces no separate benefit, and all $60,000 sits in AGI, which can influence Social Security taxation and IRMAA tiers.
The difference is the $25,000 that stays out of AGI in Path A. Whether that matters depends on the individual’s other income and thresholds.
Is the rollover worth it, or should you just take the RMD or use a DAF?
The rollover-then-QCD route tends to fit people who are at least 70½, expect to give to qualifying public charities, and want to keep distributions out of AGI. Taking the RMD and deducting can work for itemizers, while a donor-advised fund suits those who want to bunch gifts, though a DAF cannot receive a QCD (Source: IRS Publication 590-B, 2025).
| Approach | May fit when | Limitations |
|---|---|---|
| Roll 401(k) to IRA, then QCD | Age 70½+, giving to public charities, wants lower AGI without itemizing | Requires a rollout the plan allows; QCD cannot fund a DAF. |
| Take RMD, then deduct the gift | Itemizer whose total deductions clear the standard deduction | Gift enters and then leaves AGI; 2026 deduction floor and cap can trim the benefit. |
| Donor-advised fund | Wants to bunch several years of giving and advise grants over time | Not a QCD-eligible recipient; funded with post-distribution or taxable dollars. |
These are general patterns, not recommendations. The right fit depends on age, income, the type of charity, and whether you itemize. A related comparison, QCD versus Roth conversion, shows how the two strategies can work together.
In-service distributions and still-working considerations
Rolling a current employer’s 401(k) to an IRA usually requires either separation from service or an in-service distribution the plan permits, often available at age 59½. Plans differ, so the summary plan description or the administrator is the source of truth. Former-employer 401(k)s can generally be rolled out at any time (Source: IRS Retirement Plan and IRA RMD FAQs).
Someone still employed at 70½ who wants to begin QCDs faces a sequencing question. Money in an active 401(k) cannot originate a QCD and often cannot be rolled out while employed unless the plan allows in-service distributions. Where an in-service rollover is available (commonly from age 59½), eligible funds can move to a traditional IRA and QCDs can follow. Where it is not, the QCD route may have to wait until retirement or until only former-employer plan balances are involved.
The one-time QCD to a charitable gift annuity
SECURE 2.0 added a one-time election to direct a QCD to a split-interest entity such as a charitable gift annuity or charitable remainder trust. For 2026, this once-in-a-lifetime amount is $55,000 and counts within the annual QCD limit (Source: IRS Notice 2025-67). It lets an IRA owner fund a life-income gift while excluding the transfer from income.
The election is used once in a lifetime, and the $55,000 sits inside the $111,000 annual ceiling rather than on top of it. The receiving vehicle must meet the statutory requirements for a charitable gift annuity or charitable remainder trust. For most donors making straightforward gifts to operating charities, the standard QCD is simpler; the split-interest election is a narrower tool for those who want an income stream back.
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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 you make a QCD directly from a 401(k)?
No. A qualified charitable distribution is defined as a transfer made directly by the trustee of an IRA, so a 401(k) cannot originate one. The route is a direct rollover of 401(k) funds into a traditional IRA, after which the QCD is made from the IRA following the standard rules (Source: IRS Publication 590-B, 2025).
Can you donate to charity directly from a 401(k)?
You can take a distribution from a 401(k) and then donate it, but that distribution is taxable income, and a deduction helps only if you itemize. It is not a QCD. To give with the QCD exclusion, roll the 401(k) to a traditional IRA first, then have the IRA custodian send the gift directly to a qualified 501(c)(3) (Source: IRS Publication 590-B, 2025).
At what age can you make a qualified charitable distribution?
The donor must be at least 70½ on the day of the distribution, not simply in the year they turn 70½. Notably, this is earlier than the age-73 required-beginning date for RMDs, 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, the QCD generally needs to occur before any other distribution from the same IRA that year to offset the RMD (Source: IRS Publication 590-B, 2025).
What accounts can a QCD be made from?
QCDs originate only from IRAs: traditional, rollover, inherited, and inactive SEP or SIMPLE IRAs qualify. Active SEP and SIMPLE IRAs, 401(k)s, 403(b)s, 457(b)s, and the TSP do not. Roth IRAs technically permit QCDs but rarely benefit from them because Roth distributions are generally already tax-free (Source: IRS Publication 590-B, 2025).
Can you do a QCD from a 403(b), 457(b), SEP, or SIMPLE IRA?
A 403(b), a 457(b), and a Keogh (HR-10) plan cannot originate a QCD; they are employer plans, like the 401(k). A SEP or SIMPLE IRA can, but only if it is inactive, meaning no employer contribution was made for the current year. An ongoing SEP or SIMPLE that received a contribution is not an eligible source. In every case, rolling the balance to a traditional IRA first restores QCD eligibility (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, an increase from $108,000 in 2025. A married couple who each have their own IRA can reach $222,000 combined. A one-time split-interest election of up to $55,000 sits within that annual limit (Source: IRS Notice 2025-67).
Which charities are eligible to receive a QCD (do DAFs or private foundations qualify)?
A QCD can go only to a qualified public charity under IRC section 170(b)(1)(A), generally a 501(c)(3) operating charity. Donor-advised funds, private foundations, and supporting organizations do not qualify as QCD recipients. The one narrow exception is the one-time split-interest election, which can fund a charitable gift annuity or charitable remainder trust (Source: IRS Publication 590-B, 2025).
How do you report a QCD on Form 1040 line 4b?
The custodian reports the full distribution on Form 1099-R, so you self-report the exclusion. Enter the total distribution on Form 1040 line 4a, enter the taxable amount (total minus the QCD) on line 4b, and write “QCD” next to line 4b. Do not also claim the amount as a Schedule A deduction (Source: IRS Publication 590-B, 2025).
Does rolling a 401(k) into an IRA satisfy the 401(k)’s required minimum distribution?
No. If a 401(k) RMD is already due for the year, it cannot be rolled over. The RMD must be taken from the 401(k) first as taxable income, and only the balance above it can move to the IRA. That 401(k) RMD cannot be converted into a QCD, so rolling before RMDs begin avoids the issue (Source: IRS Publication 590-B, 2025; IRS RMD FAQs).
What is the QCD limit for 2026 for a married couple?
For 2026, the QCD exclusion is $111,000 per individual. A married couple who each own an IRA and are each at least 70½ can each make QCDs, reaching $222,000 combined. The limit is per person, not per household, so both spouses must use their own IRAs to reach the couple maximum (Source: IRS Notice 2025-67).
Can you still make a QCD if you are still working and contributing to your 401(k)?
Yes, but not from the 401(k) itself. If you are at least 70½ and have a traditional IRA, you can make a QCD from that IRA even while still employed and contributing to a 401(k). The active 401(k) cannot originate a QCD, and it often cannot be rolled out until you separate from service or the plan allows an in-service distribution (Source: IRS Publication 590-B, 2025).
Do you have to itemize to claim a QCD, and how is it different from an RMD?
No itemizing is required. A QCD is excluded from income rather than deducted, so it helps whether or not you itemize. An RMD is the minimum you must withdraw once you reach the required age; a QCD is a charitable transfer that can satisfy that RMD while keeping the amount out of adjusted gross income (Source: IRS Publication 590-B, 2025).
Sources
IRS, Publication 590-B (2025), “Distributions from Individual Retirement Arrangements (IRAs).” | IRS, “Seniors can reduce their tax burden by donating to charity through their IRA,” irs.gov/newsroom. | IRS Notice 2025-67 (2026 cost-of-living adjustments; QCD annual limit $111,000 and one-time split-interest amount $55,000). | IRS, “Retirement Plan and IRA Required Minimum Distributions FAQs” (SECURE 2.0 Act Section 107; RMD applicable age 73, and 75 for those reaching 74 after 2032; still-working exception). Internal Revenue Code section 408(d)(8).
