Saver’s Match and Roth IRAs: the pass-through route
Short version: Roth IRA contributions count toward the match, but the match itself can’t be paid directly into a Roth IRA. The IRS and Treasury are considering a pass-through through a conduit traditional IRA.
1. Roth contributions count
Qualified retirement savings contributions include contributions to a traditional or Roth IRANotice 2026-48, Q&A B-2.
2. The match can’t go straight into a Roth
By law, the accounts that can receive the match directly from Treasury are a traditional (non-Roth) IRA, or the non-Roth portion of a 401(k), 403(b), or governmental 457(b) planNotice 2026-48, sec. III; Q&A D-1.
3. The proposed Roth pass-through
- You open a Roth IRA with a Roth IRA provider that has registered with Treasury and the IRS, and put that provider’s IRA tracking number on Form 8880-ANotice 2026-48, Q&A E-2(b).
- Treasury does not pay the Roth IRA directly. It would set up a conduit traditional IRA for youNotice 2026-48, Q&A E-2(b).
- The money would move immediately by trustee-to-trustee transfer from the conduit IRA to your Roth IRANotice 2026-48, Q&A E-2(b).
- That transfer would be a Roth conversion, subject to federal income tax and reporting under Treas. Reg. § 1.408A-4, and to withholding rules under section 3405Notice 2026-48, Q&A E-2(b).
If your Roth provider isn’t registered
The notice describes a workaround: open a traditional IRA with a registered traditional IRA provider, receive the match there, then direct a trustee-to-trustee transfer to your existing Roth IRA. That transfer would also be a Roth conversionNotice 2026-48, fn. 26. A provider that accepts the match for both account types would register separately as a traditional and as a Roth provider and get distinct tracking numbersNotice 2026-48, fn. 25.
Roth 401(k)/403(b)/457(b)
The plan portion that can receive the match directly excludes a qualified Roth contribution programNotice 2026-48, Q&A D-1. For plans, the IRS is considering several paths (including a registration path that uses a conduit IRA and a rollover)Notice 2026-48, Q&A E-3.