Amended pension reporting regulations to require scheme administrators and insurers to provide valuation and beneficiary data for inheritance tax purposes starting April 2027.
These Regulations establish new information-sharing obligations to facilitate the application of inheritance tax to unused pension funds and death benefits for deaths occurring on or after 6 April 2027.
They require pension scheme administrators and insurance companies to provide personal representatives and HMRC with details regarding the value of pension assets, the identity of beneficiaries, and any tax amounts withheld or paid.
The instrument applies to scheme administrators, insurance companies, personal representatives of deceased members, and beneficiaries of registered pension schemes.
Arguments For
The explanatory note states that these amendments support changes made by the Finance Act 2026, which bring most unused pension funds and death benefits within the scope of inheritance tax.
The document indicates the regulations provide the necessary framework for personal representatives, beneficiaries, and scheme administrators to exchange the data required to determine tax liabilities.
The legislation mandates electronic communication for all reportable events, which the explanatory note frames as a standard requirement for supplying information to Revenue and Customs.
The order specifies strict timelines—ranging from 14 to 28 days for most requests—to ensure the timely settlement of estate taxes.
Arguments Against
Legal specialists may note that the reliance on "provisional estimates" for notional pension property, as permitted in regulations 10C and 10D, could lead to initial administrative inaccuracies in tax filings.
Pension scheme administrators might argue that the requirement to provide detailed beneficiary data, including National Insurance numbers and specific trust details under regulation 10E, increases their administrative burden.
Beneficiaries may have concerns regarding the reduction of their entitlements when scheme administrators pay inheritance tax directly to HMRC before final distributions are settled.
The interplay between different notification periods (some starting from the date of request and others from the date beneficiaries are decided) may create procedural complexity for personal representatives managing multiple schemes.
Citation, commencement and effect
- -(1) These Regulations may be cited as the Registered Pension Schemes (Provision of Information) (Miscellaneous Amendments) Regulations 2026 and come into force on 6th April 2027.
- (2) Subject to paragraph (3) the amendments made by these Regulations have effect for the tax year 2027-28 and subsequent tax years.
- (3) Regulation 3 and regulations 5 to 8 have effect in relation to deaths occurring on or after 6th April 2027.
This section establishes the official name of the regulations and sets the commencement date as 6 April 2027.
It specifies that most of the new reporting requirements apply specifically to instances where a pension scheme member dies on or after that date.
The rules govern tax years from 2027-28 onwards.
Amendments to the Registered Pension Schemes (Provision of Information) Regulations 2006
- The Registered Pension Schemes (Provision of Information) Regulations 2006 are amended in accordance with regulations 3 to 7.
This section serves as a formal instruction to modify the existing 2006 Regulations.
It lists the subsequent regulations (3 through 7) that contain the specific textual changes and additions.
Amendments to regulation 2
- In regulation 2(1) (interpretation) at the appropriate places insert-
''beneficiary' for the purposes of regulations 10C to 10M in relation to a deceased member of a pension scheme, has the meaning given in section 226B(9) of IHTA 1984;';
''charities' for the purposes of regulations 10C and 10D has the meaning given in paragraph 1 of Schedule 6 to the Finance Act 2010;';
''death in service payment' means a payment provided for in section 150A(6)(d) of IHTA 1984;';
''excluded benefit' has the meaning given in section 150A(6) of IHTA 1984;';
''exempt beneficiary' has the meaning given in section 29A of IHTA 1984;';
''IHT account' means the account provided for in section 216 of IHTA 1984;';
''IHT reference number' means a number generated by or on behalf of the Commissioners in relation to deceased individuals where an IHT account is appropriate for their estate;';
''IHTA 1984' means the Inheritance Tax Act 1984;';
''notional pension property' has the meaning given in section 150A of IHTA 1984;';
''payment notice' has the meaning given in section 226B(1) of IHTA 1984;';
''personal representatives' for the purpose of regulations 10G to 10M has the meaning given in section 272(1) of IHTA 1984;';
''prospective personal representative' has the meaning given in section 226A(12) of IHTA 1984;';
''registered clubs' for the purposes of regulations 10C and 10D has the same meaning as in Chapter 9 of Part 13 of the Corporation Tax Act 2010;';
''withholding notice' has the meaning given in section 226A(3) of IHTA 1984.'.
This section inserts several technical definitions into the primary 2006 Regulations to ensure consistency with the Inheritance Tax Act 1984 and later Finance Acts.
It defines essential terms such as 'notional pension property,' which refers to pension assets included in an estate, and 'IHT reference number,' used for tracking estate tax accounts.
These definitions establish the scope of the parties and types of payments covered by the new reporting duties.
Amendments to regulation 3
- -(1) Regulation 3 (provision of information by scheme administrator to the Commissioners) is amended as follows. (2) In paragraph (6)(b) after '(7)' insert ', (8)'.
This section makes a technical correction to the rules governing how pension scheme administrators report information to HMRC. It ensures a specific event (referenced as event 20A) follows the correct timing requirements for reporting.
This amendment addresses a previous omission in the 2018 regulations.
Amendment to regulation 8
- -(1) Regulation 8 (death: provision of information by scheme administrator to personal representatives) is amended as follows. (2) For paragraphs (1), (1A) and (2) substitute- '(1) Where a payment of a relevant lump sum death benefit has resulted in the deceased member's lump sum and death benefit allowance being expended, the scheme administrator of a registered pension scheme must provide to the personal representatives of a deceased member of that scheme-
- (a) the information specified in paragraph (1A), and
- (b) the information specified in paragraphs (2) and (3) further to a request by the personal representatives of the deceased member of that scheme. (1A) The information specified in this paragraph is-
- (a) the name of the scheme and the name and address of the scheme administrator of the scheme,
- (b) each relevant reference number, if any, in relation to the deceased member, and
- (c) the amount of the relevant lump sum death benefit paid. The information is to be provided no later than the last day of the period of 3 months beginning with the day on which the final such payment is made. (2) The information specified in this paragraph is-
- (a) the name, address, date of birth, and, if applicable and if known, the national insurance number of each individual to whom a relevant lump sum death benefit in respect of the deceased member has been paid under the scheme,
- (b) for each individual referred to in sub-paragraph (a), the amount of the member's lump sum and death benefit allowance expended by, and the amount and the date of payment of, each relevant lump sum death benefit paid by the scheme in relation to the member, and
- (c) for each payment referred to in sub-paragraph (b), confirmation of the amount, if any, by which each individual's entitlement to the lump sum death benefit was reduced because of an adjustment under section 226B(6) of IHTA 1984. The information in paragraph (2) must be provided no later than the end of the period of one month beginning with the date on which the scheme administrator receives the request from the personal representatives.'.
This section updates the duties of pension scheme administrators to share data with the executors or administrators of a deceased member's estate.
If a lump sum death benefit is paid that exhausts the member's tax-free allowance, the administrator must automatically report basic scheme and payment details within three months.
Upon request, administrators must also provide personal details of recipients and confirm if any payments were reduced to account for inheritance tax liabilities.
Amendments to regulation 10
- -(1) Regulation 10 (death: provision of information by personal representatives to the Commissioners) is amended as follows. (2) In paragraph (2)-
- (a) omit the 'and' at the end of sub-paragraph (c), and
- (b) after sub-paragraph (c) insert-
- '(ca) for the individual referred to in sub-paragraph (bb), confirmation of the amount (if any) by which that individual's entitlement to the lump sum death benefit was reduced because of an adjustment under section 226B(6) of IHTA 1984; and'. (3) In paragraph (3)(b), for '30 days' substitute '2 months'.
This section amends the requirements for personal representatives when they report to HMRC. They must now include information about how much a beneficiary's pension entitlement was reduced due to inheritance tax adjustments.
It also extends the deadline for personal representatives to provide this information to HMRC from 30 days to two months.
Death: provision of information amendments
- After regulation 10B (death: provision of information by trustee to beneficiary) insert-
' Death: provision of information by scheme administrator to personal representatives
10C. -(1) The scheme administrator of a registered pension scheme must provide to the personal representatives of a deceased member of that scheme the information specified in paragraph (2). [Section continues with detailed information requirements and 28-day response period, including valuations and beneficiary exempt status]...'
[Full text of inserted Regulations 10D to 10M follows, detailing obligations for insurance companies, procedures for withholding notices, transfers, and confirmation of IHT payments].
This section inserts ten new regulations (10C through 10M) that create a comprehensive framework for information exchange.
Regulations 10C and 10D require administrators and insurers to provide valuations and beneficiary category percentages to personal representatives within 28 days of a request.
Regulations 10E and 10F mandate the provision of more granular details, such as beneficiary addresses and National Insurance numbers, when a full Inheritance Tax account is required.
Regulations 10G through 10I manage 'withholding notices,' which are used to prevent the distribution of funds until tax issues are resolved, and require administrators to notify beneficiaries if such a notice is received.
Finally, Regulations 10J through 10M require administrators to issue formal confirmations to both beneficiaries and personal representatives whenever they pay inheritance tax or interest directly to HMRC from the scheme assets.
Amendment to the Registered Pension Schemes and Overseas Pension Schemes (Electronic Communication of Returns and Information) Regulations 2006
- -(1) The Registered Pension Schemes and Overseas Pension Schemes (Electronic Communication of Returns and Information) Regulations 2006 are amended as follows. (2) In Schedule 1 (information which must be supplied to Revenue and Customs by an approved method of electronic communications), in the entry beginning 'An event report' omit 'in any of entries 1 to 8A and 10 to 21 and 24'.
This section mandates that all information reported to HMRC by pension schemes must be submitted electronically through approved methods.
By removing specific entry limitations, it ensures that all reportable events, including those newly introduced by these regulations, are covered by the electronic communication requirement.
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