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How do SECURE 2.0 and 2024/2025 legislation change RMD start ages for pre-2026 Roth conversions?
Executive summary
SECURE 2.0 raised the RMD starting age to 73 for most people (with a scheduled increase to 75 for those born in 1960 or later effective in 2033), and it eliminated lifetime RMDs from employer‑sponsored Roth accounts beginning in 2024 for account owners — changes that create a larger window for pre‑2026 Roth conversions but do not let you convert an actual RMD itself (you must take the year’s RMD before converting other funds). Cite: RMD age change and Roth 401(k) rule [1] [2], and the prohibition on converting RMDs [3] [4].
1. What SECURE 2.0 actually changed about RMD ages — the headline
SECURE 2.0 moved the general RMD start age to 73 for people who reach age 72 after Dec. 31, 2022 (with a later statutory increase to 75 for those born in 1960 or later, effective in 2033), so for most retirees the first mandatory distribution is now tied to age 73 and the April‑1 first‑RMD deferral rule still applies (first RMD due April 1 following the year you reach the trigger age) [1] [2].
2. Employer Roth accounts: lifetime RMDs eliminated — why that matters
The law eliminated lifetime RMDs for designated Roth accounts in employer plans (for the account owner) beginning in 2024, aligning many Roth 401(k)/403(b) plans more closely with Roth IRAs and reducing forced taxable withdrawals from those balances during your lifetime [2] [5]. That change expands tax‑free accumulation options and may affect whether you prioritize converting IRA assets to Roth versus keeping money in an employer Roth account [5].
3. Conversions and sequencing: you cannot convert an RMD itself
The IRS and major advisors are clear: if you’re subject to RMDs in a tax year you must withdraw the RMD amount first — that RMD cannot be converted to a Roth. You can, after taking the RMD, convert additional non‑RMD funds to a Roth; but the year’s required withdrawal is excluded from conversion [3] [4] [6].
4. Practical effect for people doing Roth conversions pre‑2026
Because SECURE 2.0 raised the RMD age to 73 (with some people pushed later), many taxpayers now have extra years before RMDs force taxable withdrawals — this creates a wider window to do tax‑efficient Roth conversions while in lower brackets. Advisors cited by reporting say delaying RMD start or eliminating plan Roth RMDs offers planning opportunities to convert pre‑RMD balances into Roths to reduce future RMDs and taxable income [5] [7]. But remember: once you hit RMD age, you must take the RMD first each year and pay tax on that amount [4].
5. Interaction with 2024–2025 regulatory changes and transition relief
The IRS issued final regulations and transition relief that affect inherited‑account RMD timing and administrative deadlines; several sources note the final regs apply beginning in 2025 for many RMD technicalities and that transition relief for missed beneficiary RMDs through 2024 ended, meaning beneficiaries may need to resume annual RMDs in 2025 [8] [9] [10]. These regulatory moves complicate planning if you inherit accounts or are planning conversions across account types and years.
6. Limits, penalties, and practical sequencing to remember
SECURE 2.0 reduced the excise tax for missed RMDs and changed other rules, but penalties remain material — you must follow sequencing rules (take the RMD first) and track the five‑year rules and conversion timing for tax and penalty exposure. Fidelity, the IRS, and conversion guides reiterate that conversions don’t substitute for RMDs and emphasize taking required distributions by the deadlines tied to age [6] [4] [1].
7. Competing perspectives and planning tradeoffs
Sources agree SECURE 2.0 creates planning opportunities but differ on timing urgency: some advisers urge taking advantage of the delay to perform conversions in low‑income years before RMDs or Social Security/RMDs push you into higher brackets [5] [7]. Others caution conversions after you’ve reached RMD age are costlier because you still must withdraw the RMD and pay tax on conversions as ordinary income, reducing the net benefit [11] [7].
8. Bottom line and recommended next steps
SECURE 2.0 gives many people extra years before mandatory RMDs and removes lifetime RMDs for employer‑sponsored Roths, widening the window for pre‑RMD Roth conversions — but the law does not let you convert the RMD itself. Taxpayers should (a) confirm their personal RMD trigger age and deadlines with the IRS guidance and plan documents [1] [2], (b) take any year’s RMD before making conversions [3] [4], and (c) consult a tax advisor to model conversion timing versus current/future tax brackets and new regulatory deadlines [8] [9].
Limitations: available sources do not mention any post‑2025 congressional changes beyond SECURE 2.0 or give individualized tax rates; specifics here are drawn from the cited regulatory and adviser summaries [2] [3] [4].