The Roth Five-Year Rule Is Two Rules: One Lifetime Clock and One Per Conversion

A Roth IRA carries two five-year periods, and the Treasury regulation that defines them keeps them in different questions. One appears in A-1 and A-2 of 26 CFR 1.408A-6, Distributions; the other appears in A-5 of the same section. They start on different days, they are counted for different purposes, and the regulation says the two "need not be the same." Most summaries of the "Roth five-year rule" describe one period and leave the reader to assume the other is the same one.

The two-part test in A-1

A-1(b) of the regulation states that "A distribution from a Roth IRA is not includible in the owner's gross income if it is a qualified distribution or to the extent that it is a return of the owner's contributions to the Roth IRA (determined in accordance with A-8 of this section)." It then defines the term. A qualified distribution "is one that is both—(1) Made after a 5-taxable-year period (defined in A-2 of this section); and (2) Made on or after the date on which the owner attains age 59½, made to a beneficiary or the estate of the owner on or after the date of the owner's death, attributable to the owner's being disabled within the meaning of section 72(m)(7), or to which section 72(t)(2)(F) applies (exception for first-time home purchase)."

Two conditions, joined by "both." Age alone does not qualify a distribution, and elapsed time alone does not qualify one either. The five-year period referenced here is the one defined in A-2 — not any other five-year period that may also be running.

Clock one: A-2 starts it once and never restarts it

A-2 fixes the start date this way: "The 5-taxable-year period described in A-1 of this section begins on the first day of the individual's taxable year for which the first regular contribution is made to any Roth IRA of the individual or, if earlier, the first day of the individual's taxable year in which the first conversion contribution is made to any Roth IRA of the individual."

Three features of that sentence do most of the work. The period begins on the first day of a taxable year, not on the day money moved. It looks to the year for which a regular contribution is made, which is not always the year in which it is deposited. And a conversion contribution can start it too, if it comes earlier.

A-2 then closes the door on restarting: "Thus, each Roth IRA owner has only one 5-taxable-year period described in A-1 of this section for all the Roth IRAs of which he or she is the owner." Not one per account, not one per contribution. Opening a second Roth IRA at a different custodian in 2026 does not create a second period, and the regulation provides no restart mechanism. The one adjustment appears in A-2's own closing sentence: "For purposes of this A-2, the amount of any contribution distributed as a corrective distribution under A-1(d) of this section is treated as if it was never contributed."

A-7 extends that past death: "The beginning of the 5-taxable-year period described in A-1 of this section is not redetermined when the Roth IRA owner dies." For a surviving spouse who treats the account as his or her own, A-7(b) says the period "ends at the earlier of the end of either the 5-taxable-year period for the decedent or the 5-taxable-year period applicable to the spouse's own Roth IRAs." Earlier, not later.

A first regular contribution made on April 15, 2027 for tax year 2026 puts the start date at January 1, 2026 and the end at December 31, 2030 — 1,356 days after the money actually arrived, or three years and eight months of real possession satisfying a period the regulation calls five taxable years.

Clock two: A-5 starts a new period with every conversion

A-5 answers a different question — whether the 10-percent additional tax under section 72(t) applies. Subsection (a) covers the ordinary case: the tax "will apply (unless the distribution is excepted under section 72(t)) to any distribution from a Roth IRA includible in gross income."

Subsection (b) is the one that surprises people. "The 10-percent additional tax under section 72(t) also applies to a nonqualified distribution, even if it is not then includible in gross income, to the extent it is allocable to a conversion contribution, if the distribution is made within the 5-taxable-year period beginning with the first day of the individual's taxable year in which the conversion contribution was made." A converted amount was already taxed in the year of conversion, so pulling it back out is not a second income event. A-5(b) attaches the 10 percent to it anyway, and only to the taxed part: "For purposes of applying the tax, only the amount of the conversion contribution includible in gross income as a result of the conversion is taken into account."

Subsection (c) states the separation directly. "The 5-taxable-year period described in this A-5 for purposes of determining whether section 72(t) applies to a distribution allocable to a conversion contribution is separately determined for each conversion contribution, and need not be the same as the 5-taxable-year period used for purposes of determining whether a distribution is a qualified distribution under A-1(b) of this section."

The regulation supplies its own illustration, still written in the dates of its original issuance. A calendar-year taxpayer takes a traditional IRA distribution on December 31, 1998, converts it on February 25, 1999, and makes a regular contribution for 1998 on that same day. The result: "the 5-taxable-year period for purposes of this A-5 begins on January 1, 1999, while the 5-taxable-year period for purposes of A-1(b) of this section begins on January 1, 1998."

What December 31 and January 2 do to the same dollar

Because A-5(b) runs from the first day of the taxable year in which the conversion was made, the calendar date of a conversion changes the end date in steps of a full year. A conversion completed on December 31, 2026 sits in tax year 2026; its period ends December 31, 2030, which is 1,461 days after the transaction. A conversion completed on January 2, 2027 sits in tax year 2027; its period ends December 31, 2031, which is 1,824 days after the transaction. Two days apart on the calendar, 365 days apart at the finish line.

Inside a single tax year the effect runs the other way: a conversion on January 1, 2026 waits 1,825 days to clear its own period, a conversion on December 31, 2026 waits 1,461, and both clear on the same date. That 364-day spread is the cost of the taxable-year convention — the same convention that lets a single day of December eligibility fill a whole year's HSA limit and start a 13-month testing period.

An owner who converts in several years runs several of these at once. Take a first regular contribution for tax year 2022 and conversions in 2023, 2024 and 2026: the A-2 period ends December 31, 2026, and the three A-5 periods end December 31, 2027, December 31, 2028 and December 31, 2030. Four end dates, one account, and the earliest is not the one that controls the 10-percent question on the newest conversion.

The ordering rules decide which clock is being tested

Which period applies depends on which layer of the account a withdrawal is treated as coming from, and the owner does not choose. A-8(a) states that "Any amount distributed from an individual's Roth IRA is treated as made in the following order (determined as of the end of a taxable year and exhausting each category before moving to the following category)—(1) From regular contributions; (2) From conversion contributions, on a first-in-first-out basis; and (3) From earnings." A-8(b) adds a rule inside the middle layer: "To the extent a distribution is treated as made from a particular conversion contribution, it is treated as made first from the portion, if any, that was includible in gross income as a result of the conversion."

The same three layers appear as line items on IRS Form 8606, Nondeductible IRAs. In Part III of the 2025 revision, line 22 is "Enter your basis in Roth IRA contributions" and line 24 is "Enter your basis in conversions from traditional IRAs and rollovers from qualified retirement plans to a Roth IRA." Regular contributions are subtracted first, conversions second, and whatever survives both subtractions is the taxable remainder.

Where the second clock stops mattering

A-5(b) ends with a sentence that determines who ever feels the conversion period at all: "The exceptions under section 72(t) also apply to such a distribution." The IRS table of exceptions in IRS, Retirement topics — Exceptions to tax on early distributions lists, under Age, distributions made "after participant/IRA owner reaches age 59½," citing section 72(t)(2)(A)(i).

Combined with A-5, that collapses the map. For a dollar allocable to the taxed portion of a conversion, the combinations resolve like this.

Situation at the time of distribution	Income tax on that dollar	10 percent under 72(t)
Under 59½, inside that conversion's own A-5 period	No — A-5(b) applies "even if it is not then includible in gross income"	Yes, unless another 72(t) exception applies
Under 59½, past that conversion's A-5 period	No	No
59½ or older, inside that conversion's A-5 period	No	No — the 72(t)(2)(A)(i) age exception applies
59½ or older, past the A-2 period	No; and earnings are also untaxed, because the A-1 test is met	No

The conversion period therefore does its work in one cell only. Past 59½ it is inert; before 59½ it can attach 10 percent to money that produces no taxable income at all. The A-2 period does the opposite: it never touches conversion principal, and governs only the earnings layer, where a failure means ordinary income tax plus, under A-5(a), the 10 percent unless excepted.

The income test that gates one of A-2's two triggers

A-2 gives two possible triggers for the lifetime period: the first regular contribution or, if earlier, the first conversion contribution. Whether the first of those is available at all depends on an income test the IRS republishes every year. In IRS Notice 2025-67, 2026 Amounts Relating to Retirement Plans and IRAs, "For singles and heads of household, the income phase-out range is between $153,000 and $168,000, increased from between $150,000 and $165,000." For married couples filing jointly the 2026 range is "between $242,000 and $252,000," and for a married individual filing separately the range "is not subject to an annual cost-of-living adjustment and remains between $0 and $10,000." The same notice sets the 2026 ceiling under section 219(b)(5)(A), which "is increased from $7,000 to $7,500."

Those ranges are read the same way as the traditional-side band, where modified AGI goes in and the 2026 IRA deduction comes out in $10 steps. A-2 names two triggers, and above the top of the range the first of them drops out, so a conversion contribution is the only trigger left standing in the text of A-2. Whether a conversion is in fact permitted at that income level is not established by anything quoted in this article.

The floor rose $31,000 across the eight years and the ceiling rose the same $31,000, which is why the band stayed exactly $15,000 wide from 2019 through 2026. The same account pair splits at four separate thresholds in the 2026 tax year, and this income test is only one of them.

Numbers to Re-check

Figure	Value used here	Year this article is written on	Where it is published	What replaces it
IRA contribution ceiling, section 219(b)(5)(A)	$7,500	2026	IRS Notice 2025-67	The notice that publishes the following year's amounts
Roth contribution phase-out, single and head of household	$153,000 to $168,000	2026	IRS Notice 2025-67	Same notice cycle
Roth contribution phase-out, married filing jointly	$242,000 to $252,000	2026	IRS Notice 2025-67	Same notice cycle
Roth contribution phase-out, married filing separately	$0 to $10,000	2026	IRS Notice 2025-67	Stated there as "not subject to an annual cost-of-living adjustment"
Additional tax rate on a non-excepted early distribution	10 percent	Current regulation text	26 CFR 1.408A-6 A-5, citing section 72(t)	Statutory change only
Form 8606 Part III line numbers 22, 24 and 25a	2025 revision, Cat. No. 63966F	2025 form year	IRS Form 8606	Each annual revision; line numbers can move
Currency of the regulation text quoted here	"up to date as of 9/08/2026"	As displayed on eCFR	eCFR, title 26	Updated continuously

Where This Doesn't Apply

This reading is limited to what 26 CFR 1.408A-6 says about Roth IRAs held by an individual owner on a calendar taxable year. Designated Roth accounts inside an employer plan are not Roth IRAs, and this section does not address them; A-2 speaks only of "any Roth IRA of the individual." A fiscal-year taxpayer does not get the January 1 start dates used throughout this article, because A-2 and A-5 both anchor on "the first day of the individual's taxable year." And A-5(b) says "The exceptions under section 72(t) also apply to such a distribution" — the IRS exceptions table runs well beyond the age entry quoted above, and whether any particular one applies is a fact question this article does not reach.

The regulation text is also older than the statute it implements. Its examples are written in 1998 and 1999 dates, and A-6 addresses a four-year income spread available only for 1998 conversions. More pointedly, 26 CFR 1.408A-4, Converting amounts to Roth IRAs, in the same subject group and displayed by eCFR as current to September 8, 2026, still reads at A-2: "An individual with modified AGI in excess of $100,000 for a taxable year is not permitted to convert an amount to a Roth IRA during that taxable year." Notice 2025-67 publishes phase-out ranges for taxpayers making contributions to a Roth IRA and publishes no corresponding figure for conversions. Whether that $100,000 sentence remains operative is not answered anywhere inside section 1.408A-6 and is not established by anything quoted here; it is a question for current-year IRS guidance and for section 408A itself. Nothing in the two periods described above depends on it.

Finally, none of this addresses whether a conversion or a distribution is a good idea. The regulation defines when a period starts and when it ends, and says nothing about whether it should be waited out.

This article explains how the rules are written. It is not tax, legal, or insurance advice, and it does not account for any individual situation. Amounts and thresholds change; verify the current figures at the source listed above before acting.