Collective money purchase scheme — registration for unconnected multiple employers
Published 26 November 2025
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Who is likely to be affected
This measure will affect pension scheme administrators seeking to register a collective money purchase (CMP) scheme.
General description of the measure
The measure will enable unconnected, multiple employer CMP schemes to apply to HMRC to become a registered pension scheme and allow HMRC to refuse to register or to de-register an unauthorised CMP scheme. The government will also take a regulation-making power to allow HMRC to legislate for CMP schemes more efficiently in the future.
Policy objective
This measure will allow for the smooth operation of the Department for Work and Pensions’ upcoming legislation on the expansion of CMP schemes, allowing commencement without delay. The measure will also enable HMRC to more efficiently legislate for any relevant and required changes to enable CMP benefits to be provided, including under the ‘guided retirement’ provisions being legislated for under the Pension Schemes Bill 2025.
Background to the measure
The Pension Schemes Act 2021 introduced CMP schemes (also known as collective defined contribution (CDC) schemes) as a new type of trust based occupational pension scheme. Currently CMP schemes are only available to single or connected employers. However, the Department for Work and Pensions (DWP) are expanding this to allow for unconnected, multiple employer schemes (UMES).
As UMES are not intended to be used for employees of the person establishing the scheme, they are not occupational pension schemes (OPS) for tax purposes. Where a scheme is not an OPS, unless the person setting up the scheme has permission under the Financial Services and Markets Act 2000 (FISMA) to establish a personal pension scheme or stakeholder pension scheme, an application to register the scheme cannot be made.
CMP schemes, like Master Trust schemes, are required to be authorised by the Pensions Regulator (TPR) to be able to operate lawfully. HMRC has the ability to decide not to register or to de-register a Master Trust scheme that is not authorised by TPR. Current legislation could require HMRC to register a CMP scheme that failed TPR authorisation requirements.
Detailed proposal
Operative date
The measure will have effect from the date of Royal Assent to Finance Bill 2025-26. However, the provisions relating to UMES will be operational only after the Department for Work and Pensions UMES legislation has taken effect.
Current law
The current law is:
- Part 4 of Finance Act 2004 (as amended by subsequent Finance Acts and supporting regulations)
- Pension Schemes Act 2017 (as amended by subsequent Acts and supporting regulations)
- Pension Schemes Act 2021 (as amended by subsequent Acts and supporting regulations)
Proposed revisions
The government will introduce legislation in Finance Bill 2025-26 so that certain CMP schemes are:
- treated as occupational pension schemes (OPS) for tax purposes
- capable of applying to HMRC to be registered for tax purposes under Part 4 of Finance Act 2004
- capable of being refused registration by HMRC if the CMP scheme is not authorised by TPR
- capable of being de-registered if the CMP scheme becomes unauthorised
The government will also introduce a regulation making power so that HMRC can more efficiently legislate for necessary changes to CMP schemes or benefits in the future.
Summary of impacts
Exchequer impact £ million)
| 2025 to 2026 | 2026 to 2027 | 2027 to 2028 | 2028 to 2029 | 2029 to 2030 | 2030 to 2031 |
|---|---|---|---|---|---|
| Nil | Nil | Nil | Nil | Nil | Nil |
This measure is not expected to have an Exchequer impact.
Macroeconomic impact
This measure is not expected to have any significant macroeconomic impacts.
Impact on individuals, households and families
The proposed change will affect pension scheme administrators only and is not expected to have any impact on individuals, households and families.
The measure is not expected to impact on family formation, stability or breakdown.
Equalities impacts
The proposed change will only affect pension scheme administrators, therefore, it is not anticipated that there will be any disproportionate impacts on those in groups sharing protected characteristics.
Administrative impact on business including civil society organisations
This measure is expected to have no impact on business and civil society organisations’ administrative burdens, with no one-off costs or continuous costs.
The measure will not disproportionately impact certain business sectors since it is a technical change to the legislation.
This measure is expected overall to have no impact on businesses’ experience of dealing with HMRC as the change does not impact the way they would interact with HMRC.
Operational impact (£ million) (HMRC or other)
There will be no operational impact on HMRC as a result of this measure.
Other impacts
Other impacts have been considered, and none have been identified.
Monitoring and evaluation
This measure is a change to an existing policy owned by DWP. It will be monitored as part of the existing monitoring an evaluation plan of that existing policy.
Further advice
If you have any questions about this change, contact HMRC Pensions Tax Policy team at policypensions@hmrc.gov.uk.