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Brief

IHT on pensions from April 2027

Updated 14 October 2026
pensions-taxinheritance-taxdeath-benefitsestatesscheme-administration

Relevant to AdvisersIFAsAdministratorsIn-house / scheme managers

Applies to All schemes

From 6 April 2027, most unused pension funds and death benefits will be included within the value of a person’s estate for Inheritance Tax (IHT) purposes HMRC. HMRC ties the reform directly to the abolition of the Lifetime Allowance: removing the cap on tax-relievable pension savings had reinforced the use of pensions as a wealth-transfer vehicle, and this measure reverses that incentive HMRC. The change applies equally to DC and DB schemes and removes the current distinction between discretionary schemes — most UK schemes, where trustees decide who receives death benefits and the funds sit outside IHT today — and non-discretionary schemes such as the NHS and judicial schemes, where the member’s nomination is binding and the funds are already inside IHT. Both come into scope HMRC. This is the standalone treatment of a strand also summarised in Pensions tax — abolition of the Lifetime Allowance, the new lump sum allowances, annual allowance, and IHT on pensions.

Scope and exclusions

In scope from 6 April 2027 are most unused pension funds and death benefits held in UK-registered pension schemes and QNUPS (Qualifying Non-UK Pension Schemes) HMRC. Unauthorised payments made from a deceased member’s pension fund remain in scope of IHT HMRC.

The government’s July 2025 response carved out several categories:

Who is liable and how it works

The liability model changed at the response stage. The October 2024 technical consultation proposed that pension scheme administrators (PSAs) report and pay the IHT on the pension component. After 649 written responses and nine HMRC workshops, the government dropped that model — principally because it would needlessly draw the more than three-quarters of affected estates with no IHT liability into the process, would push PSAs to pay “on account” at the maximum 40% rate to avoid interest and so delay payouts, and sat awkwardly with a six-month deadline that discretionary-scheme processes can take a year or more to meet HMRC.

Instead, from 6 April 2027 personal representatives (PRs) — who already administer the rest of the estate — are liable for reporting and paying the IHT on unused pension funds and death benefits. Pension beneficiaries become jointly and severally liable with the PR for the IHT on the benefits they are entitled to, from the point they are appointed (not the fixed 12-month trigger of the original PSA-led design) HMRC. A PR’s personal liability is limited to the value of assets passing directly through the estate HMRC.

The scheme administrator’s information duties. The process opens when PRs contact the deceased’s pension schemes to notify death and confirm whether there is a surviving spouse or civil partner. The PSA must then tell the PR the value of the pension for IHT purposes — all relevant unused funds and death benefits as at date of death — within four weeks of receiving that notification HMRC. Once its own process completes (discretionary schemes take longer, given the trustees’ discretionary decision), the PSA tells the PR how the benefits split between exempt beneficiaries (spouses/civil partners) and non-exempt beneficiaries, and supplies beneficiary identity information as the PR needs it for the IHT account HMRC. Where a beneficiary directs the PSA to pay their IHT, the PSA issues a certificate (amount paid, IHT reference, date of payment, beneficiary identity) to the beneficiary and the same information to HMRC alongside the payment. Once all benefits are distributed, the PSA confirms full distribution to the PR and provides lump-sum amounts and identities so the PR can check the deceased’s Lump Sum and Death Benefit Allowance was not exceeded HMRC. The existing Registered Pension Schemes (Provision of Information) Regulations 2006 govern current PSA/PR information sharing; the new IHT information-sharing framework is to be added by separate secondary legislation (see Still to come) HMRC. Schemes must also make the liability position clear to non-exempt beneficiaries when informing them of their benefits — flagging that IHT may be due and setting out their payment options HMRC.

Three routes to settle the IHT on the pension component HMRC:

  1. Pay from the free estate. The PR pays the IHT on the whole estate, including the pension component, from the free estate and then applies for probate. Where the free-estate and pension beneficiaries differ, the PR uses its existing right of reimbursement under the Inheritance Tax Act 1984 to reclaim the pension-attributable IHT from the pension beneficiaries.
  2. The beneficiary directs the PSA to pay (a new scheme to be set up). The PR settles IHT on the free estate; the appointed beneficiaries direct the PSA to pay the pension IHT to HMRC on their behalf. These PSA-directed payments are authorised payments and are not subject to Income Tax.
  3. The beneficiary takes the benefits in full and pays the IHT directly to HMRC, then contacts HMRC to reclaim any Income Tax paid on the amount equal to the IHT charge.

The deadline and liquidity. The standard IHT payment deadline — six months after the end of the month of death — is retained for pensions; the government declined to extend it despite consultation requests for 12 months or two years, and late-payment interest accrues after that point HMRC. PRs have the usual liquidity aids: the Direct Payment Scheme (drawing on the deceased’s bank and building-society accounts pre-probate), payment by annual instalments, and a grant on credit. HMRC’s analysis is that for taxpaying estates affected in 2027–28 the pension makes up less than 5% of net estate value in more than half of cases, and less than 60% in almost all cases — so PRs will usually be able to pay from the wider estate HMRC.

Interaction with Income Tax. Income Tax is not charged on the slice of relevant death benefits equal to the IHT due on that pension HMRC. The wider Income Tax treatment still turns on age at death: for deaths under 75, death benefits are typically taken free of Income Tax; for deaths at 75 or over, they are taxed as income at the recipient’s marginal rate HMRC. Directing the PSA to pay (route 2) avoids the double charge because the payment is authorised and not itself income-taxed; a beneficiary who does not so direct may pay Income Tax on the benefits and then have to reclaim it from HMRC, for which HMRC is to build systems and guidance HMRC.

The information-sharing machinery: SI 2026/818

The information-flow framework that this process depends on — flagged as pending secondary legislation in the sources through mid-2026 — was made on 13 July 2026 and laid before the Commons on 15 July 2026 as The Registered Pension Schemes (Provision of Information) (Miscellaneous Amendments) Regulations 2026 (SI 2026/818), coming into force on 6 April 2027 leg. It is the machinery instrument supporting Part 2 of the Finance Act 2026, and gives statutory form to the terminology the 11 May 2026 technical note introduced — notional pension property, withholding notices, payment notices — by tying each to the new IHTA 1984 sections that FA 2026 inserted (s150A notional pension property; s226A/s226B withholding and payment notices; s29A exempt beneficiary) leg. Its amendments have effect for tax year 2027-28 onwards, save that the death-keyed provisions (regs 3 and 5–8) apply to deaths on or after 6 April 2027 leg. It amends two 2006 instruments: the Registered Pension Schemes (Provision of Information) Regulations 2006 (SI 2006/567) and the Electronic Communication Regulations 2006 (SI 2006/570) leg.

The core disclosure duties (new regs 10C–10M of SI 2006/567). The SI inserts a graduated set of duties on scheme administrators and, in annuity cases, insurance companies leg:

Amendments to the existing death-reporting duties. Reg 8 of SI 2006/567 (scheme administrator to PRs) is recast so that, once a lump sum death benefit has expended the member’s Lump Sum and Death Benefit Allowance, the administrator must supply the headline details within 3 months of the final payment and the fuller dataset within 1 month of a PR request — now including confirmation of any reduction to a beneficiary’s entitlement from a s226B(6) IHTA 1984 adjustment. Reg 10 (PRs to HMRC) gains the matching confirmation and its time limit moves from 30 days to 2 months leg.

Mandatory electronic filing. Reg 8 of the SI amends the Electronic Communication Regulations 2006 so the electronic-communication requirement now extends to all reportable events in the reg 3(1) event-report table (removing the previous carve-out for certain entries) leg. The SI’s own Tax Information and Impact Note is the one published on 26 November 2025 with the Budget/Finance Bill, which it states remains accurate leg.

Technical Note 2 (27 August 2026): the process detail lands

The “further technical note” trailed in Newsletter 183 arrived on 27 August 2026 as Inheritance Tax on Pensions: Technical Note 2, and HMRC is explicit that it is “not draft guidance” HMRC. Its role is to explain the made regulations rather than a proposal: where Technical Note 1 (11 May 2026) described the mechanism, TN2 works through SI 2026/818 stage by stage. The underlying policy is unchanged — commencement on 6 April 2027, scheme administrator liability for reporting and paying the IHT on notional pension property, and the nil-rate-band apportionment model all stand as previously set out (same source). What is new is process, and it is where the operational risk now sits.

One duty was narrowed after consultation. Following responses to the consultation on the draft regulations, scheme administrators need only inform personal representatives about excluded benefits, and give details of them, where an Inheritance Tax account is actually required HMRC. That is a meaningful reduction: it keeps the great majority of estates — the three-quarters of the 213,000 with no IHT liability at all — out of the excluded-benefits reporting channel entirely.

The excluded-benefits boundary, and where it bites

TN2 confirms which benefits sit outside notional pension property: dependants’ scheme pensions, trivial commutation lump sum death benefits derived from commuting one, dependants’ and nominees’ annuities purchased together with the member’s lifetime annuity, and death-in-service lump sums HMRC. The dependants’ scheme pension exclusion carries a trap worth flagging to administrators: it applies only where the pension is payable solely as an excluded benefit under s.150A(6) IHTA 1984. If the beneficiary had a choice of another death benefit type — a dependants’ annuity, say — the benefit is not excluded, even where a scheme pension is ultimately what they take (same source). The exclusion turns on the option set, not the outcome. There is no requirement that a dependant’s scheme pension be paid at a constant rate to stay excluded, and excluded or not, it remains taxable as pension income in the beneficiary’s hands (same source).

Death in deferment is the other boundary to get right. Where a member dies while deferred, most death benefits and unused funds are in scope; a lump sum on a deferred member’s death does not normally qualify as death-in-service and so is not excluded, though someone treated as still employed under a redundancy package or the scheme rules may still qualify depending on those terms HMRC.

On the exemptions, TN2 draws a line administrators will welcome: a scheme administrator must report the proportion of notional pension property expected to pass to charities or registered clubs, to a surviving spouse or civil partner, and to other exempt beneficiaries — but is not required to determine whether a spouse or civil-partner transfer actually qualifies as exempt. For charity and club beneficiaries the assessment is made “with reference to publicly available information” (same source). The administrator reports the split; it does not adjudicate the exemption.

Where the administrator picks up joint liability

Three routes turn a process failure into the scheme’s own tax bill, and they are the reason the day-counts below matter:

And a scheme cannot draft its way out: under s.226B(8) IHTA 1984 any scheme rule that would prohibit or restrict payment of IHT in response to a valid payment notice is void to that extent HMRC. Trustees reviewing rules ahead of April 2027 should note that this is one clause they need not amend — but also one they cannot rely on.

The clocks, the caps and the floor

TN2 sets out the day-counts in detail for the first time. All are calendar days HMRC:

DutyDeadline
Basic information — value (or estimate) of notional pension property (regs 10C(2)/10D(2))28 days from receipt of the request
Information on potentially-exempt beneficiaries, where beneficiaries not yet determined14 days from the day they are determined
Confirming the final valuation where an estimate was given14 days from the actual value being ascertained
Further information where an IHT account is required (regs 10E/10F)later of 28 days from request or 14 days from the beneficiary decision
Withholding notice the administrator considers invalid — notify submitter to rectify, with reasons14 days from receipt
Withholding notice accepted — notify the PR of acceptance14 days
Withholding notice accepted — provide the total amount withheld28 days
Prescribed information to each decided beneficiary under a withholding notice14 days
Transfer of withheld rights to another scheme or insurer (reg 10H) — inform the PRlater of 14 days from transfer or 14 days from notice receipt
Paying under a valid payment notice (s.226B(2)(b) IHTA 1984)35 days from receipt of a valid notice
Post-payment information to the beneficiary or PR (regs 10J(3)/10L(3)/10M(3))14 days from the date of payment
Reporting relevant tax-free lump sum death benefits to the PR (new reg 8(1A))3 months from the final such payment
Further LSDBA information on request (reg 8(2))1 month from receipt of the request

Two of those repay a second look. The 35-day payment clock runs only from a valid notice — so the 14-day invalidity challenge is the administrator’s control on its own exposure, not a courtesy. And the reg 8(1A) three-month LSDBA reporting duty is genuinely new in the amending SI HMRC. On the PR side, new reg 10(2)(ca) requires PRs to tell HMRC whether any lump sum death benefit payments were reduced under s.226B(6), and reg 10(3)(b) extends that reporting period from 30 days to 2 months (same source).

The quantitative limits:

Tax paid to HMRC directly from the pension under the Direct Payment Scheme is not subject to Income Tax — though a subsequent HMRC repayment of an overpayment may be, and an overpayment is returned to the PR to pass on to the beneficiary rather than netted against the wider estate liability HMRC.

Who counts as a personal representative — two definitions, deliberately

A subtlety TN2 spells out for the first time: “personal representative” carries two different statutory meanings depending on which duty is in play. For the information-request regulations 10C–10F, the general Income Tax definition at s.989 Income Tax Act 2007 applies and covers prospective PRs; for withholding and payment notices under regs 10G–10M, the inclusive definition at s.272 IHTA 1984 applies, with “prospective personal representative” separately defined at s.226A(12) IHTA 1984. The practical consequence: a prospective PR can request information and issue a withholding notice, but cannot issue a payment notice HMRC. Administrators building identity and authority checks should not use one test for both channels.

Insurers paying annuities sourced from a pension scheme are generally subject to the same obligations and deadlines as scheme administrators, with two stated differences: the withholding provisions do not apply to insurers that are not registered pension schemes, and their excluded-benefit reporting is limited to dependants’ and nominees’ annuities purchased with the member’s lifetime annuity HMRC.

The transitional edge, and clearance

Pre-6 April 2027 deaths are not brought into scope retrospectively — but the reform reaches them one generation on. Once notional pension property has vested in a beneficiary, it forms part of that beneficiary’s own estate on their death. HMRC’s Example 8 makes the point starkly: a member dying 4 July 2026 attracts no IHT on her pension, but the £200,000 her son inherited into beneficiary drawdown is included in his notional pension property when he dies 1 November 2030 HMRC.

On clearance, PRs should apply on form IHT30 only once the IHT account and schedules are in, all IHT is believed paid and estate values are believed final — which in practice means waiting until at least 12 months after the date of death and at least 3 months after receiving the unique code for probate. A Clearance Checker tool will be updated for pensions. Once clearance is granted, liability for IHT on later-discovered pension benefits falls on the pension beneficiaries, not the PRs — though PRs remain responsible for reporting them HMRC.

The road to April 2027

TN2 publishes a dated forward-look HMRC:

Annexes A to C of TN2 — draft guidance on evidencing PR identity and authority, and draft withholding notice and payment notice templates — are all labelled draft, with final versions to follow on GOV.UK (same source). Schemes building processes now should treat the templates as a reliable shape but not a final form.

The numbers

HMRC estimates around 213,000 UK estates a year will hold inheritable pension wealth in 2027–28. Of these, about 10,500 (roughly 1.5% of all UK deaths) become newly liable to IHT where they would not have been before, and a further ~38,500 pay more IHT than previously HMRC. For that second group the average existing IHT liability was forecast at £169,000, rising by around £34,000 once pension assets are included (figures from the October 2024 consultation; the July 2025 response repeats the headline counts but frames them as an upper limit once behavioural change — faster drawdown, greater use of other reliefs — is allowed for) HMRC. More than three-quarters of the 213,000 estates are expected to have no IHT liability at all, yet would have been drawn into the process under the originally-proposed PSA-led model — a key reason it was dropped HMRC. For context, fewer than 10% of all UK estates a year are forecast to carry any IHT liability; the nil-rate band is £325,000 (transferable to a spouse or civil partner, up to £650,000 combined) with a residence nil-rate band of up to £175,000 (up to £350,000 combined) HMRC.

Government restated the same framing in the Commons in September 2026, with two figures worth holding: the combined nil-rate bands mean an estate can pass on up to £1 million with no IHT liability, and more than 90% of UK estates will continue to have no IHT liability in 2030-31 even after the change. Transfers to a spouse or civil partner — including death benefits — remain fully exempt. The same answer put the gross cost of income tax and National Insurance relief on pensions at £83.9 billion in 2024-25 WQ. Note that the corpus also holds an earlier figure of £78.2 billion for 2023-24 WQ — different years, not a revision.

Why “2030-31”, and why the £1m figure is not a moving target. Both halves of that restatement were fixed at Budget 2025 and have not shifted since. On 17 November 2025 — nine days before the Budget — the Financial Secretary to the Treasury gave the Lords the same three numbers the Commons heard in September 2026: an estate can pass on up to £1 million free of IHT using the combined nil-rate bands, spouses and civil partners remain fully exempt, and more than 90% of UK estates will still have no IHT liability after the change. The cost of pension tax relief was put at £78 billion a year in that exchange Hans. The “2030-31” horizon in the later answer comes from the Budget itself: on 2 December 2025 the Commons resolved to amend s.86 of the Finance Act 2021 so that the nil-rate band, the residential enhancement and the taper threshold “remain at their current amounts for the tax year 2030-31” — a further year of freeze on top of the existing one Hans. So the £1m headroom is frozen in cash terms through the whole of the first four years of the pension charge, and estates drift towards it as asset values rise. The same sitting carried the enabling resolution for the charge itself — Resolution 51, “Inheritance tax (pension interests)”, allowing provision “about the charging of inheritance tax by reference to benefits payable under a pension scheme on the death of a member of the scheme” — on a division of 364 to 167 Hans.

HMRC’s operational readiness

Because the April 2027 design puts the burden on personal representatives rather than scheme administrators, HMRC’s own bereavement-facing service capacity becomes part of the risk. Two service measures are now on the record. HMRC’s standard for IHT30 clearance applications is 80% within 15 working days; in Q1 2026-27 it processed 93% within that period. Its Bereavement Helpline, introduced on 17 June 2025, answered calls in an average of 7 minutes 58 seconds across 2025-26, improving to 5 minutes 4 seconds over April–June 2026 WQ.

Those are pre-reform baselines, measured before roughly 213,000 estates a year begin holding inheritable pension wealth in the IHT process. Advisers setting client expectations on probate and clearance timescales for deaths after 6 April 2027 should treat them as the starting point rather than the forecast — and administrators should note that a PR who cannot get timely clearance is a PR who will press the scheme on the withholding and payment-notice machinery described above.

The measure’s passage through the Finance (No.2) Bill

Before the Bill, the policy had to survive a Lords Oral Question on 17 November 2025 that put the two objections practitioners still hear. The first was retrospectivity — that savers had built pots and made long-term plans on the old treatment. The Financial Secretary rejected it flatly and on a narrow ground: the charge “takes effect for deaths on or after 6 April 2027, so that is in no way retrospective.” The second was the alternative design: a flat-rate levy on unused pensions, recovering some of the relief given without a 40% marginal hit. That was considered and refused, on distributional grounds — a flat-rate tax “would mean that 90% pay more so that 10% can pay less” Hans. The Government’s own framing of the purpose was equally direct: the change “removes distortions resulting from changes made over the last decade, which have led to pensions being openly used and marketed as a tax planning vehicle to transfer wealth, rather than to fund retirement” Hans. Two administrative asks were also refused in that exchange, both relevant to the PR timetable in IHT on pensions — administrator readiness checklist: extending the six-month window before late-payment interest begins (the Minister’s answer was that six months “is standard within the tax system”), and any assurance about the future of the 25% tax-free lump sum, on which the Minister declined to speculate ahead of a Budget Hans.

The charge was legislated through the Finance (No.2) Bill, whose Commons committee sittings in January 2026 took clauses 63 to 68 — bringing unused pension funds and death benefits into the estate from 6 April 2027, the personal representative liability, and the 15-month withholding mechanism described above HansHansHans. Scrutiny also ran in the Lords, where the administrative burden on personal representatives was raised directly in the Spring Forecast debate and referred to the Lords Finance Bill Sub-Committee Hans. The same Bill carried clause 57, aligning HMRC and TPR treatment of collective DC and master trusts and enabling multi-employer CDC from 31 July 2026 — see Collective Defined Contribution (CDC) / Collective Money Purchase Schemes Hans.

Where the politics stood two weeks before the 28 October 2026 Budget

The charge is legislated, but it is not politically settled, and anyone being asked by a client whether it might still be pulled should know what the most recent test of that showed. On 14 October 2026 the Opposition used a Commons day to move “[t]hat this House calls on the Government to cut public spending in order to abolish Inheritance Tax on family homes, farms and businesses” Hans. Three features of that debate matter for planning purposes, and the first is the most useful.

The motion did not ask for the pensions measure to be reversed. Its three named targets are family homes, farms and businesses; the Conservative proposition set out in the debate was a single £500,000 per person allowance (£1 million per couple) replacing current allowances, together with the full restoration of agricultural and business property relief (same source). Unused pension funds were raised repeatedly from the Opposition benches as a grievance — Blake Stephenson (Mid Bedfordshire) (Con) that “unspent pensions will also be dragged into the liability”, Gregory Stafford (Farnham and Bordon) (Con) that a couple’s £1 million headroom looks different “once we add a family home in my constituency to a lifetime of savings and, from April 2027, their pension pots”, Rebecca Smith (South West Devon) (Con) that pensions “are not inherited wealth, but money that has been earned and set aside” — but no speaker committed any party to repealing the April 2027 charge (same source). The measure has no stated reversal commitment attached to it from either front bench.

Neither Treasury Minister engaged with it. The Financial Secretary and Paymaster General, James Murray, opened and the Exchequer Secretary, Dan Tomlinson, wound up; neither mentioned unused pension funds, the 6 April 2027 start, scheme administrators or personal representatives at any point, and the only reply from the Government benches came from a backbencher, Catherine West (Hornsey and Friern Barnet) (Lab), who said that “a commitment has been made not to tax those who only receive the state pension” and that those who “earn a lot, whether through pensions, inheritance or other things, will be taxed proportionately” (same source). That is not a statement of the measure’s design and should not be read as one — the authoritative statements of purpose and scope remain the November 2025 Lords exchange and the technical notes set out above.

The frozen bands that do the work are confirmed, and the Budget date is fixed. Murray told the House the Chancellor “will deliver his Budget in this House on 28 October” and that the Government “do not comment on speculation”; he put IHT as “currently payable on around one in 20 estates” and forecast to raise “almost £15 billion in 2030-31”, against the £325,000 nil-rate band frozen to April 2031 as described from the Opposition benches (same source). The freeze is the multiplier on this article’s numbers: it is what turns the addition of a pension pot to the estate into a charge for estates that would not previously have paid. The motion was negatived on a division (the capture records division 86 at 18:59 with unlabelled figures of 99 and 291) (same source).

The practical reading for IHT on pensions — administrator readiness checklist is unchanged and, if anything, firmer: nothing in the last parliamentary test of the policy before the Budget suggests the April 2027 commencement will move, and no party has undertaken to unwind it. Schemes and personal representatives should continue to build to the timetable in the road to April 2027.

Still to come before April 2027

Several pieces are explicitly flagged as pending in the sources — this is very much a live workstream:

The 11 May 2026 technical note — informed by industry feedback and reflecting that the reforms were legislated in Finance Act 2026 — gives further detail on how the legislation will operate for PRs, PSAs and beneficiaries, and introduces terminology not in the 2025 documents (“notional pension property”, “withholding notices” and a confirmed “pensions direct payment scheme”); the full note is a linked attachment not captured verbatim here, so that detail is not further elaborated in the corpus HMRC. Newsletter 181 (28 May 2026) confirms HMRC will keep using the pension schemes newsletter over the coming year to flag what stakeholders need to prepare for and to signpost guidance as it appears HMRC.

What schemes should be doing now

Administrators should anticipate the operational duties the process design imposes once live: responding to a PR’s death notification with the pension’s IHT valuation within four weeks; determining and communicating the exempt / non-exempt beneficiary split; explaining to non-exempt beneficiaries that IHT may be due and their three settlement routes; supporting the PSA-direct-payment route (issuing certificates of IHT paid and reporting to HMRC); and confirming full distribution to the PR with lump-sum details for the Lump Sum and Death Benefit Allowance cross-check HMRC. They should be ready — subject to the still-pending secondary legislation — to share beneficiary identity details (name, address, date of birth, NI number) with PRs once an IHT account is confirmed as required; no record-retention period is fixed in these sources HMRC.

A related operational deadline sits in the same window: the pension schemes online service is being withdrawn, and PSAs are told to migrate all open schemes to the Managing Pension Schemes service by 31 December 2026. Newsletter 183 firms up the closure date the earlier newsletter left open — the online service closes from April 2027, the same month the IHT change commences — and warns of service limitations as that date nears; schemes to be wound up rather than migrated should follow Newsletter 180 (April 2026) HMRCHMRC.

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