The rule, in the law's own words
A QCD has to go to a charity described in section 170(b)(1)(A) of the tax code, "other than any organization described in section 509(a)(3) or any fund or account described in section 4966(d)(2)." Section 4966(d)(2) is the definition of a donor-advised fund. So the exclusion is written into the statute, not just into custodian policy.
The IRS put it plainly when it explained the rule: "donor-advised funds and supporting organizations are not eligible recipients." Custodians say the same; Fidelity lists donor-advised funds among the charities that "may not qualify for QCDs." The 2025 tax law did not change any of this.
Sources: the tax code, IRC section 408(d)(8)(B)(i) and section 4966(d)(2); IRS, IRA transfers to charity; IRS Notice 2007-7, Q&A 35; Fidelity, Qualified charitable distributions.
What happens if the money goes to a fund anyway
It is not a QCD. The money that left your IRA is an ordinary withdrawal and counts as income for the year. Whether a deduction for the gift to the fund makes up for that depends on whether you itemize and on your income limits, which is a question for your tax preparer.
Is Congress changing it?
Two bills would let QCDs go to donor-advised funds. Neither has passed, and neither has moved past committee:
- H.R. 2891, the IRA Charitable Rollover Facilitation and Enhancement Act of 2025, introduced April 10, 2025 by Rep. Adrian Smith. Latest action: referred to the House Ways and Means Committee the same day.
- S. 3975, the Senate version, introduced March 3, 2026 by Sen. Todd Young. Latest action: referred to the Senate Finance Committee the same day.
Both would strike the donor-advised fund exclusion for gifts made after the bill becomes law. Supporting organizations would still be excluded. Until then, the rule above stands. Status checked on Congress's official records on October 14, 2026.
Sources: Congress.gov, H.R. 2891 (bill text) and S. 3975; Rep. Adrian Smith, press release.
What works instead
Send the QCD straight to the charity you would have granted to. A direct gift to an operating charity is exactly what the law was written for: the money stays out of your income, and in a year you owe a required minimum distribution, it counts toward that too. NYC Honor qualifies. It is a 501(c)(3) public charity, and its IRS classification, 509(a)(2), is not an excluded category.
If you already hold a donor-advised fund, keep using it for the money that is already there. How to grant to NYC Honor from your fund.
Give from your IRA to NYC Honor
If you are 70½ or older, you can send a gift straight from your IRA to NYC Honor. For 2026 you can give up to $111,000 this way, per IRS Notice 2025-67, and the gift stays out of your taxable income.
- Pay to
- NYC Honor Foundation Inc.
- EIN
- 42-1836369
- Mail the check to
- 7720 82nd St, Glendale, NY 11385-7635
What to tell your IRA custodian:
To count for 2026, the check has to leave your IRA by December 31, so give your custodian a few weeks. Curious what the gift saves you? Try the QCD calculator.
Custodian checks often arrive without your name on them. Tell us it's coming so we can thank you and send the acknowledgment you'll need for your taxes.
This is education, not advice
NYC Honor Foundation is a charity, not a tax or investment advisory firm. Talk to your own tax professional before you move money. Checked against the sources named on this page on October 14, 2026.