Two clocks, side by side
Publication 590-B points out that the 5-year period for conversions is not necessarily the same as the one used to decide whether a distribution is qualified. They measure different things and they start at different times.
| Qualified distribution clock | Conversion clock | |
|---|---|---|
| How many | One per person, across all Roth IRAs | One per conversion |
| Starts | January 1 of the first tax year a contribution was made for | January 1 of the year of the conversion |
| Ends | December 31 of the fifth year | December 31 of the fifth year |
| What it decides | Whether earnings come out tax free | Whether the 10% additional tax hits the converted amount |
| Also needs | Age 59½, disability, death, or a first home (up to $10,000) | Nothing; age 59½ or another exception removes the 10% anyway |
Clock 1: tax-free earnings
A distribution is qualified, and completely tax free, if it is made after the 5-year period beginning with the first tax year for which a contribution was made to a Roth IRA set up for you, and it is also made on or after age 59½, because you are disabled, to a beneficiary after your death, or for a first home up to a $10,000 lifetime limit. The regulation adds the details that matter for dates: each owner has only one such period, it begins on the first day of the tax year the first contribution was made for, and it ends on the last day of the fifth consecutive year. If a conversion comes before any contribution, the period starts on January 1 of the year of that conversion.
The key word is "for". A contribution made between January 1 and the April filing deadline can count for the previous tax year, and then the clock starts on January 1 of that earlier year. Publication 590-B's own example has a 2024 contribution made in 2025 starting its period on January 1, 2024. So a contribution made in the spring for the year before puts up to about 15 months on the clock at once.
| First Roth IRA money | Clock starts | Clock ends | Earnings can be qualified from |
|---|---|---|---|
| Contribution for 2025, made April 15, 2026 | January 1, 2025 | December 31, 2029 | January 1, 2030 |
| Contribution for 2026, made December 30, 2026 | January 1, 2026 | December 31, 2030 | January 1, 2031 |
| Contribution for 2026, made April 1, 2027 | January 1, 2026 | December 31, 2030 | January 1, 2031 |
| Conversion made November 2, 2026, before any contribution | January 1, 2026 | December 31, 2030 | January 1, 2031 |
Opening another Roth IRA later does not restart anything, and the regulation says the start date is not redetermined when the owner dies. Heirs count the original owner's years, which inherited IRA rules covers from the beneficiary's side.
Clock 2: one per conversion
Publication 590-B says a separate 5-year period applies to each conversion and rollover, starting on the first day of the tax year of the conversion. Its example: a conversion made on February 25, 2025 starts its period on January 1, 2025. If you take out the part of a conversion that was included in income during that period, you generally owe the 10 percent additional tax on it, unless an exception applies. The exceptions include reaching age 59½, disability, being the beneficiary of a deceased owner, a first home and substantially equal payments; the full list is in early withdrawal penalty exceptions.
This clock does not decide income tax. The converted amount was already taxed in the conversion year, as Roth conversion explained shows, and Publication 590-B treats it as not includible again. Unlike the contribution date, a conversion always counts for the calendar year it happens in.
A backdoor Roth contribution is a conversion too, so it starts its own clock; the steps are in the backdoor Roth guide.
Which dollars come out first
Both clocks only matter for the dollars a withdrawal actually reaches, and the ordering rules decide that. Publication 590-B treats a distribution that is not qualified as coming out in this order:
- Regular contributions. Never taxed and never subject to the 10 percent, at any age.
- Conversion and rollover contributions, first in, first out by year, and within each conversion the taxable part before the nontaxable part. No income tax again, but the 10 percent can apply inside that conversion's 5 years.
- Earnings. Taxable as income unless the distribution is qualified, plus the 10 percent if you are under 59½ and no exception applies.
All your Roth IRAs count together: you add up all distributions from all of them during the year, and all contributions. The taxable part of a distribution that is not qualified is figured on Form 8606, Part III. The custodian's side of the paperwork is in Form 1099-R explained.
Case 1: first contribution in April, earnings out after 59½
A saver aged 57 opens her first Roth IRA with $7,000 on April 15, 2026, designated for tax year 2025, and adds $7,500 for 2026. Her clock starts January 1, 2025 and ends December 31, 2029. In June 2029, now past 59½, she withdraws the whole $18,000.
| June 2029 withdrawal | Amount | Tax |
|---|---|---|
| Regular contributions | $14,500 | None |
| Earnings | $3,500 | Income tax; no 10%, she is over 59½ |
The withdrawal is not qualified because the 5 years end on December 31, 2029. Waiting until January 1, 2030 would have made all $18,000 tax free. Being over 59½ is not enough on its own.
Case 2: a conversion at 45
A 45-year-old has $10,000 of regular contributions in a Roth IRA from years ago and converts $30,000 of pre-tax traditional IRA money on March 10, 2027, paying income tax on all of it for 2027. That conversion's clock runs from January 1, 2027 to December 31, 2031. In 2029 he takes out $16,000.
| 2029 withdrawal | Amount | Tax |
|---|---|---|
| Regular contributions, first | $10,000 | None |
| Taxable part of the 2027 conversion, next | $6,000 | No income tax; 10% additional tax $600 |
The same withdrawal in 2032 or later would cost nothing: the conversion's 5 years are over, and the ordering rules still reach earnings last. His contributions are always free to take out.
Case 3: a first Roth IRA opened at 62 by conversion
A 62-year-old with no Roth IRA converts $40,000 in 2026. Both clocks start on January 1, 2026: the conversion is the first Roth money, so it also starts the qualified-distribution clock. In 2028 she takes out $25,000. That comes from the conversion, already taxed in 2026, and she is past 59½, so neither income tax nor the 10 percent applies, even though the conversion is only two years old. What she cannot yet take tax free is earnings: any growth withdrawn before January 1, 2031 is taxable income, because the qualified-distribution clock is still running.
Checking your own dates
- Find the tax year of your very first Roth IRA contribution, or your first conversion if that came first. Add 5 to the year: January 1 of that year is when earnings can become qualified.
- List each conversion by calendar year. Each one is free of the 10 percent from January 1 five years later, or as soon as you reach 59½.
- Add up your regular contributions over the years. That total is always available, tax and penalty free.
- For growth, the retirement savings calculator and the compound interest calculator show what contributions turn into, which is the earnings layer these rules protect. If you also save at work, the 401(k) calculator projects that account; 401(k) vs IRA vs Roth IRA compares the accounts.
This guide follows IRS Publication 590-B and Treasury Regulation 1.408A-6 and is not tax advice; the IRS rules for a particular withdrawal are in Form 8606 and its instructions.
Frequently asked questions
When does the Roth IRA 5-year clock start?
On January 1 of the first tax year for which you made a contribution to any Roth IRA. A contribution made on April 15, 2026 for tax year 2025 starts the clock on January 1, 2025, so the 5 years end on December 31, 2029. If your first Roth money is a conversion, the clock starts on January 1 of the year of the conversion.
Does opening a new Roth IRA restart the 5-year clock?
No. Treasury Regulation 1.408A-6 says each Roth IRA owner has only one 5-taxable-year period for qualified distributions, measured from the first contribution to any of the owner's Roth IRAs. A second account opened later uses the same start date.
Can I take out my Roth IRA contributions before 5 years?
Yes. Under the ordering rules in Publication 590-B, regular contributions come out first, and a return of regular contributions is not included in income. The 5-year rules matter for the converted amounts and the earnings, which come out after the contributions.
Does each Roth conversion have its own 5-year rule?
Yes. Publication 590-B says a separate 5-year period applies to each conversion, starting on January 1 of the year of the conversion. Taking out the taxable part of a conversion within that period generally brings the 10 percent additional tax unless an exception applies, such as being 59½ or older.
What happens to the 5-year clock when the owner dies?
The regulation says the start of the period is not redetermined when the Roth IRA owner dies. A beneficiary counts the time the original owner held Roth IRAs, so an inherited account can pay qualified distributions once the owner's 5 years are over.
Sources
- IRS Publication 590-B (2025), Distributions from IRAs, chapter 2 (qualified distributions: after the 5-year period beginning with the first tax year for which a contribution was made, and at 59½, disability, death or a first home up to $10,000; a separate 5-year period for each conversion starting with the first day of the tax year of the conversion; the example where a 2024 contribution made in 2025 starts its period January 1, 2024; ordering rules; adding together all distributions from all Roth IRAs; Form 8606 Part III)
- Treasury Regulation 26 CFR 1.408A-6, Q&A-2 and Q&A-7 (only one 5-taxable-year period per owner, beginning with the first taxable year for which a regular contribution is made or the year of a first conversion, ending on the last day of the fifth consecutive taxable year; not redetermined when the owner dies)
- IRS Publication 590-A (2025), Contributions to IRAs (2025 contribution limit $7,000 and 2026 limit $7,500; contributions for a year can be made until the return due date without extensions, April 15, 2026 for 2025)
General information based on the sources above, not tax, legal or financial advice.