Updated July 31, 2026. Quick answer: the 529 must have been open 15 years before any Roth rollover — and the question every family asks next has no official answer: does changing the beneficiary restart the clock? The IRS has not issued guidance. We are not going to pretend otherwise, and you should distrust any article that states either answer as settled.
What is actually known
The statute starts the 15 years at the account’s opening “for the designated beneficiary” and says nothing explicit about beneficiary changes. Conservative practice — and several plan administrators — assume a change MAY restart the clock for the new beneficiary; aggressive readings assume account age travels. Until the IRS rules, the planning move is simple: open accounts early (even with $50) for anyone who might ever be a beneficiary, because an account’s birthday is the one fact you control today, and avoid unnecessary beneficiary changes on accounts approaching year 15 if a rollover is the goal.
The related-but-different 5-year rule is settled: contributions from the last five years, plus their earnings, cannot move yet — the rollover draws from the seasoned layer of the account. Both clocks are applied automatically in the rollover calculator; the alternative when the clock fails you: changing the beneficiary instead.
Unresolved rules reward early paperwork.
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