Can funds from a 401(k) be rolled to an IRA in time to use a QCD to satisfy 2026 RMDs?
Executive summary
Yes — dollars held in a workplace retirement plan such as a 401(k) can be rolled to an IRA and then used for a qualified charitable distribution (QCD) that satisfies 2026 required minimum distributions (RMDs), but only if the rollover and the IRA-to-charity transfer are completed in the proper sequence and within the RMD timing rules; QCDs are allowed only from IRAs, are available to those age 70½ and older, and the 2026 per-person QCD cap is $111,000 [1] [2] [3].
1. Why the rollover is necessary and the basic rule
A QCD must come directly from an eligible IRA — traditional, rollover, SEP or SIMPLE — and is not permitted directly from a 401(k) or other workplace plan; therefore funds remaining in a 401(k) must first be rolled into an IRA before they can be used for a QCD [1] [2] [4]. The QCD exclusion applies to donors age 70½ or older and the 2026 limit per individual is $111,000 [3] [2].
2. The sequencing trap: “first dollars out” and why timing matters
The IRS and retirement advisers emphasize a “first-dollars-out” sequencing rule: the first distributions taken from an IRA in a year are deemed to satisfy that year’s RMD, and once an RMD is taken it cannot be retroactively offset by a later QCD [5] [6]. Practically, that means the rollover must be completed and the charity must receive the QCD — or the IRA must at least record the QCD as the first IRA distribution of the calendar year — before any taxable IRA distribution is taken that would be treated as the RMD [5] [6].
3. Deadlines and the RMD calendar that govern “in time”
For most owners the annual RMD for a calendar year must be completed by December 31 of that year (with the narrow exception that a first RMD may be delayed until April 1 of the year after the first RMD year) [7]. Therefore, to satisfy 2026 RMDs with a QCD, the rollover and direct IRA-to-charity transfer must be completed by the applicable RMD deadline (typically December 31, 2026) and must occur in that calendar year before any other IRA distributions that would be treated as the first dollars out [7] [6].
4. Practical hurdles and plan-level restrictions
Plan documents and administrators sometimes restrict rollovers, and administrative processing can take days to weeks; the plan’s rules may allow participants to delay RMDs from the plan until retirement, but that does not affect IRA RMDs once balances are rolled in [7]. While the reporting here explains the legal contours, specific timelines for processing a 401(k) distribution and rollover are plan-dependent and are not specified in these sources, so individuals must confirm with their plan administrator and IRA custodian to ensure the rollover and subsequent QCD clear in time [7].
5. Reporting, limits and strategy notes
When a QCD is properly executed, the taxpayer reports the IRA distribution on Form 1040 and indicates the taxable amount is zero with “QCD” noted, and a QCD can count toward the RMD for the year while reducing the IRA balance and thus potentially lowering future RMDs [8] [9]. Advisors commonly recommend executing QCDs early in the year to avoid the sequencing mistake and to manage related tax thresholds (e.g., Social Security/Medicare IRMAA effects), and the 2026 QCD cap is $111,000 per individual [6] [5] [3].
6. Bottom line judgment
Legally and practically the pathway is clear: roll 401(k) funds to an IRA, then have the IRA make a direct QCD to charity before any other IRA distribution counts as the RMD for 2026 — and do it before the statutory deadline (typically December 31, 2026); failure to complete the rollover and QCD in that sequence or before the RMD is considered taken will prevent the QCD from retroactively satisfying the year’s RMD [1] [6] [7]. Sources document the rules and common-sense timing advice but do not provide firm processing timelines for individual plan administrators, so confirmation with custodians and charities is required to be certain the transactions clear in time [7] [6].