When rolling over a 529 plan to a Roth IRA, does it count against my annual Roth contribution limit for 2025?
I'm trying to make sure I understand this new 529-to-Roth rollover option correctly before I mess up my taxes. My sister is 34 and has about $40,000 sitting in a 529 plan that our parents set up for her. She finished grad school years ago with minimal loans, so there's still a good chunk left. She's thinking about using the lifetime conversion limit of $35,000 to roll some of that 529 money into a Roth IRA for the 2025 tax year. The question we can't figure out is whether this rollover would eat into her regular Roth IRA contribution limit for the year (which I think is like $7,500 for 2025?). Can she do BOTH the 529 rollover AND contribute the max to her Roth separately? Or does the rollover count toward her annual limit? I checked the IRS website but got confused with all the different rules and limitations. Any help would be super appreciated!
20 comments


Christian Bierman
This is a great question about an important new tax provision! The good news is that a 529 plan rollover to a Roth IRA does NOT count against the annual Roth IRA contribution limit. These are treated as two separate transactions under the tax code. Your sister can roll over up to $35,000 lifetime from her 529 to a Roth IRA (subject to yearly limits of the annual contribution amount), AND she can still make her regular annual Roth IRA contribution (which is $7,000 for 2024 and will likely be $7,500 for 2025 with inflation adjustments). The 529 rollover is considered a qualified rollover, not a contribution. There are some important requirements for the 529-to-Roth rollover though: the 529 account must have been open for at least 15 years, the beneficiary and the Roth IRA owner must be the same person, and the rollover amount in any year cannot exceed the annual Roth contribution limit for that year.
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Emma Olsen
•Wait, I'm confused about something. You said the rollover amount in any year can't exceed the annual Roth contribution limit, but also that it doesn't count against that limit? That seems contradictory. Could you explain that part again? Also, does the person need to have earned income for the 529-to-Roth conversion like you normally would for regular Roth contributions?
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Christian Bierman
•Let me clarify that point, as it is a bit confusing. While the 529-to-Roth rollover doesn't count against your annual contribution limit (meaning you can still make your regular Roth contribution), the amount you can roll over from a 529 to a Roth in any single year is capped at the annual contribution limit for that year. So for 2025, if the contribution limit is $7,500, you could roll over up to $7,500 from the 529 AND separately contribute up to $7,500 to the Roth. Yes, the beneficiary still needs to have earned income for the year equal to or greater than the amount being rolled over from the 529 to the Roth IRA. This is the same earned income requirement that applies to regular Roth contributions.
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Lucas Lindsey
I was in a similar situation with leftover 529 funds and totally confused about what to do. Then I found this amazing tool at https://taxr.ai that analyzed my specific 529 rollover situation and broke everything down for me step by step. It confirmed exactly what the previous commenter said - the 529-to-Roth conversion doesn't affect your regular contribution limit! What I really liked was that they walked me through all the specific requirements like the 15-year holding period and the earned income rules. It even helped me figure out how to time my rollovers over multiple years to optimize the tax benefits since I couldn't roll everything over at once due to the annual limits.
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Sophie Duck
•How exactly does that service work? Did you have to upload financial documents or just answer questions? I've got about $22k in my daughter's 529 that we won't need since she got a full scholarship, and I'm trying to figure out the most tax-efficient way to handle it.
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Austin Leonard
•I'm kind of skeptical about these online tax tools. Did it actually save you money compared to just talking to an accountant? And how does it handle state-specific rules? I've heard some states might treat these rollovers differently than the feds do.
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Lucas Lindsey
•The service works by asking you a series of questions about your specific situation - the 529 account details, when it was opened, your income, etc. I didn't need to upload any documents initially, though I could attach statements later for more detailed analysis. It absolutely saved me money compared to my accountant, who actually wasn't up to speed on these new rollover rules yet! As for state-specific rules, it addressed that directly - it flagged that my state (Illinois) might recapture some of the state tax deduction I originally received when contributing to the 529, which was something I hadn't even considered. It gave me a clear breakdown of federal vs. state implications.
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Sophie Duck
Just wanted to update after using taxr.ai for my 529 rollover question! You guys were right about how helpful it is. I was worried about potentially triggering penalties or missing some obscure rule, but the guidance was super clear. It confirmed I could do both the rollover AND make my regular Roth contribution since my daughter's 529 has been open for 16 years. It also pointed out something I hadn't realized - since my daughter got a scholarship, I could actually withdraw an amount equal to her scholarship from the 529 without the usual 10% penalty (though I'd still owe income tax on earnings). This gives me options to either do that OR do the Roth conversion depending on which makes more sense tax-wise in my situation. Seriously helpful tool!
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Anita George
This rollover topic is exactly why I was stuck on hold with the IRS for like 3 hours last month trying to get a straight answer! Eventually I used https://claimyr.com and got connected to an actual IRS agent in less than 20 minutes. You can see how it works in this video: https://youtu.be/_kiP6q8DX5c The agent confirmed everything that's been said here - the 529-to-Roth rollover and regular Roth contributions are separate transactions with separate limits. She also mentioned something important: you need to have the rollover go directly from the 529 plan administrator to the Roth IRA custodian for it to qualify properly. If you withdraw the money yourself first, it could mess everything up!
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Abigail Spencer
•How does this Claimyr thing actually work? I'm confused how a third-party service can get you through to the IRS faster. Isn't that like cutting in line?
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Logan Chiang
•Yeah right. No way this actually works. The IRS is deliberately understaffed to make it impossible to get help. I've literally tried calling dozens of times about my 529 questions and never got through. Sounds like you're selling something...
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Anita George
•It's not cutting in line at all. Claimyr uses a system that keeps dialing the IRS for you and navigating the phone tree until it gets a human, then it calls you to connect. It's basically doing the tedious waiting part for you. They use the same publicly available phone systems anyone can access, they just have the technology to stay on hold indefinitely and work through the various automated prompts. Nothing sketchy about it - they're just solving the problem of wasting hours on hold. It literally saved me an entire afternoon of waiting around with my phone on speaker.
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Logan Chiang
I have to eat my words about Claimyr. After my skeptical comment, I decided to try it anyway because I was desperate to get an answer about my 529-to-Roth conversion before tax deadline. I was SHOCKED when I got connected to an IRS agent in about 15 minutes after weeks of failed attempts on my own. The agent gave me detailed guidance on my specific situation. The most useful part was confirming that I needed to coordinate directly with both my 529 administrator and my Roth IRA provider to ensure the rollover was processed correctly. Apparently if you don't specify that it's a 529-to-Roth rollover, it might get processed incorrectly and create tax problems. Worth every penny to get that clarification!
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Isla Fischer
Don't forget that while the FEDERAL rules allow for this 529-to-Roth rollover without penalty, your STATE might still have its own rules! I live in New York and found out that my state might recapture some of the state tax benefits I got when I originally contributed to the 529 if I do the Roth conversion. Check your state's treasury department or tax authority website before making any moves. Some states automatically conform to federal tax changes, but others don't!
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Miles Hammonds
•Do you know which states definitely DON'T penalize for this rollover? I'm in California and wondering if I should just keep the money in the 529 for my grandkids instead.
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Isla Fischer
•I don't have a comprehensive list, but I know California doesn't offer state tax deductions for 529 contributions to begin with, so you wouldn't face a recapture issue there. States like Illinois, Michigan, and Montana have specifically indicated they might recapture previous deductions, while states like Florida have no state income tax so it's not an issue. Your best bet is to check with your specific state's tax department or use one of the tools mentioned earlier that can provide state-specific guidance. The policy landscape is still evolving since this rollover option is relatively new.
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Ruby Blake
Has anyone actually completed one of these rollovers yet? I'm trying to figure out the paperwork side of things. Do I need to contact both the 529 provider and my Roth IRA company? Is there a specific form to fill out?
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Micah Franklin
•I completed one in February! You need to contact both companies. First, call your Roth IRA provider to confirm they can accept 529 rollovers (most major ones can now). Then contact your 529 plan administrator and tell them you want to do a direct rollover to a Roth IRA. They'll have specific forms - mine had a "Qualified Rollover Distribution Request" where I had to specify it was going to a Roth IRA under the SECURE 2.0 provisions. Most important: make sure it goes DIRECTLY from the 529 to the Roth. Don't have them send you a check first or it could be treated as a non-qualified distribution!
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Ella Cofer
This is such a timely question! I went through this exact situation last year with my own leftover 529 funds. Just to add to what others have said - make sure you also check the specific timing requirements. The 529 account needs to have been open for at least 15 years, but here's something I didn't realize initially: any contributions made to the account in the last 5 years (and their earnings) are NOT eligible for the rollover. So if your parents added money to your sister's 529 within the last 5 years, that portion would need to stay in the account. The rollover can only include contributions that are at least 5 years old plus any earnings on those older contributions. This might affect how much of that $40,000 is actually eligible for the Roth conversion. I had to go back through my 529 statements to figure out which contributions qualified - definitely worth checking before you start the process!
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Alice Pierce
•This is such a crucial detail that I think gets overlooked! The 5-year lookback rule on contributions is definitely something to watch out for. Do you know if this applies to earnings as well? Like if contributions from 6 years ago generated earnings over the past 5 years, are those recent earnings still eligible for rollover? I'm trying to figure out exactly how much of my account would qualify and the earnings calculation seems tricky.
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