There is no income limit (high income will not disqualify you from making a Roth IRA contribution via a 529 rollover). But there is requirement to have compensation (earned income) in the year you do the rollover.
"Does the beneficiary need a job or have already contributed to the Roth IRA? The beneficiary must have earned income that at least equals the amount to be rolled over. For example, if you’re planning on rolling over $5,000 in 2024, your beneficiary must have earned at least $5,000 for the year."
"What if the beneficiary makes too much to contribute to a Roth? There is no earned income limit for these transfers. Normally, you can’t contribute to a Roth IRA if your modified adjusted gross income in 2024 is more than $161,000 for single filers or $240,000 for those married filing jointly."
Reference: https://www.jhinvestments.com/viewpoints/college-saving/five-things-to-know-about-rolling-a-529-acco...
So, effectively, using 529 funds to fund a Roth contribution appears to be a loop hole to the income limit, for a very few people.
