PENSION ADMINISTRATION TECHNICAL HELP

PATHways 186

Highlighting pensions news and legislation that has
particular relevance to what we do in pension administration


In this edition of PATHways, we cover:

  • Inheritance tax information sharing regulations laid
  • Government’s workplace pensions roadmap updated
  • DWP publishes consultation on general levy
  • Pension schemes newsletter 183
  • HMRC publishes draft member surplus payment legislation
     

James Freeman contributed to the writing of this newsletter.

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Inheritance tax information sharing regulations laid

The Government has laid The Registered Pension Schemes (Provision of Information) (Miscellaneous Amendments) Regulations 2026. These mainly concern the new information sharing requirements in relation to the forthcoming inheritance tax (IHT) changes. These regulations were previously consulted on in draft form. They have been amended in places after feedback from the pensions industry, most notably in the removal of a proposed new ‘Event 25’, which would have required death in service benefits to be reported automatically to HMRC.

Requirements brought in by the regulations will apply to deaths on or after 6 April 2027 and, in summary, include:

  • If the member’s lump sum and death benefit allowance (LSDBA) has been expended, details of the scheme and amounts of death lump sum paid must be issued automatically to the personal representatives (PR) of the member within three months of the payment date. Further specified details about death lump sums paid must be sent to the PR within one month by request.
  • On request from the PR, the scheme administrator must send details of the scheme and the value of the member’s ‘notional pension property’ at the date of death within 28 days. If a provisional estimate is given of the amount, the actual value must be provided within 14 days of it being determined. The percentage of the value which is exempt from IHT must also be sent to the PR on request.
  • Where a PR needs to file an IHT account, the administrator must send them various details about the scheme, the beneficiaries, and any death benefits which have been paid which are excluded from IHT, within the later of 28 days of the request or 14 days of the beneficiaries being decided upon.
  • If the scheme is given a valid ‘withholding notice’, they must provide the sender with details including whether it has been accepted and if so, the value being withheld. Impacted beneficiaries must be informed within 14 days of the notice being received or of the beneficiary being identified, if later.
  • Where the scheme has paid IHT by deduction from the death benefit as a result of receiving a valid ‘payment notice’, the PR and the beneficiary whose entitlement to death benefits has been reduced, must be informed within 14 days of payment being made to HMRC, or 14 days of being identified as a beneficiary if this is later.

HMRC Pension schemes newsletter 183

HM Revenue & Customs (HMRC) has published Pension schemes newsletter 183, with information including:

  • Notification of an online “interactive guidance tool” on the Pension schemes general enquiries web page which replaces the previous email method for pension schemes wishing to contact HMRC. 
  • Summaries of the member surplus payment and inheritance tax legislative developments which are covered elsewhere in this issue.
  • Confirmation that a further ‘technical note’ will be published ‘later this summer’ with information and examples of the new process for inheritance tax (IHT) on pensions, including the withholding and payment notices which administrators will need to deal with from April 2027.

Government’s workplace pensions roadmap updated

The Department for Work & Pensions (DWP) has published an updated ‘Roadmap’ in relation to workplace pension reform. This sets out the Government’s intended aims for reform and the updated indicative timescales for those changes. This covers both defined benefit (DB) and defined contributions (DC) related pension reform, such as regulations on DB ‘superfunds’, which are currently expected to come into force in late 2028, and the consolidation of certain DC ‘small pots’ from April 2030. 

DWP publishes consultation on general levy

The DWP has also published a consultation on proposed changes to the rates and structure of the General Levy, for the period April 2027 to March 2030. This levy supports the funding for various bodies, including the Pensions Regulator and Pensions Ombudsman. 

The Government wants to place the levy-funded bodies on a more sustainable footing with an increase to the levy rates. 

It has proposed a 5% per year increase for DB scheme levies across the three year period. For DC occupational schemes the yearly increase would be 6.2% and for Master Trusts and personal pensions 9%. This is with the aim of gradually moving towards equalisation between the rates payable by different scheme types. The consultation closes on 8 September 2026.

PASA new and updated guidance

The Pensions Administration Standards Association (PASA) has published new and updated guidance during June 2024 in several of the areas its working groups cover.

Data Presence vs Accuracy 

The PASA Data Working Group continues to produce content regularly and has published new guidance on ‘Data Presence vs Accuracy’. The main part of the guidance focuses on what trustees can do to improve data accuracy, suggesting trustees conduct an audit of data quality to identify potential issues in their data and areas of weakness, and on reviewing the data accuracy, carry out data remediation work as necessary. The guidance also suggests that consideration is given to ongoing monitoring on a periodic basis to help ‘future proof’ data accuracy.

Master trust transitions guidance

The PASA Master Trust Working Group has published updated guidance on master trust transitions following on from the original version issued in November 2019.

The updated guidance accounts for developments in the master trust space in the intervening years and is designed for situations involving transitions of savers to and from master trusts, focusing on the two most common scenarios:

  • master trust to master trust; and
  • single employer trust to master trust.

As well as industry developments, other topics covered include transition planning and suggested project governance, and communications.

HMRC publishes draft member surplus payment legislation

HMRC has also published draft legislation and an accompanying policy paper intended to enable DB occupational pension schemes make discretionary payments directly to eligible members from a scheme surplus. It is currently expected to allow these payments to be made on or after 6 April 2027.

The policy is part of the Government’s reforms aiming to unlock the economic value within pension schemes. It follows on from those provisions of the Pensions Schemes Act 2026 and the related consultation intended to make it easier for schemes in surplus to make payments to the sponsoring employer.

The draft legislation would allow schemes to pay an ‘authorised member surplus payment’ when the required conditions are met. These would be taxable at the recipient’s marginal income tax rate and would not count towards either the member’s pension input amount for annual allowance purposes or their lump sum allowance.

HMRC has asked for feedback on the draft legislation to be submitted by 7 September 2026.

DWP – combining small pension pots

The Department for Work and Pensions (DWP) announced on 24 April 2025 plans to bring eligible small pension pots together under reforms to be included in the Pension Schemes Bill, as part of the Government’s Plan for Change.  It follows the findings of the work conducted by the Small Pots Delivery Group aimed at supporting the design and implementation of the new small pots multiple consolidator scheme approach,  The aim of the initiative is to:

  • automatically combine the number of eligible small pots of £1000 or less into one pension scheme that is certified as delivering good value to savers.  Individuals will retain the right to choose their own consolidator scheme or opt out;
  • help workers keep track of their pensions and get a better rate of return on these retirement savings by reducing the number of flat rate charges paid from their multiple small funds; and
  • save businesses millions in unnecessary costs involved with administering an increasing number of small funds, as a result of Automatic Enrolment. 

Read previous edition

PATHways 185 - Pension Administration Technical Help

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Read previous edition

PATHways 184 - Pension Administration Technical Help

Download now

Read previous edition

PATHways 183 - Pension Administration Technical Help

Download now

 

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