Guidance

Newsletter 180 — April 2026

Published 23 April 2026

Pension scheme return (PSR)

If you receive a notice to file a pension scheme return for the 2025 to 2026 tax year and a pension scheme return was submitted for the 2024 to 2025 tax year, some information will be pre‑populated to make the submission process easier.

To start compiling your pension scheme return, you will need to select the relevant scheme from your list of schemes on the managing pension schemes service and select ‘Pension scheme return’ under the ‘manage reports and returns’ section.

If you have received a notice to file, there will be an option to select ‘Start’ next to the ‘6 April 2025 to 5 April 2026’ tax year.

Viewing and searching a submitted pension scheme return

On the managing pension schemes service, you can view or search any version of a compiled or submitted pension scheme return for a tax year.

To view any compiled or submitted return on your pension scheme’s record, select the tax year and version you want to view.

You can search member details by using their name or National Insurance number to see the information you submitted about them.

Filing or amending pension scheme returns for the tax year 2023 to 2024, or earlier

If you need to submit a new pension scheme return or amend a previously submitted pension scheme return for the tax year 2023 to 2024 or earlier, you will need to do this on the pension schemes online service.

You can no longer submit any pension scheme returns on the pension schemes online service, for any period, using third party software. You’ll need to compile and submit the report directly onto the service.

Lifetime allowance protection and enhancements – reminder

In pension scheme newsletter 179 — March 2026 we told you the protection look up service is now available on the managing pension schemes service.

This is a reminder that the unauthenticated look up route is closed.  If you try to access the previous route, you’ll be redirected to sign in to the managing pension schemes service.

Please share this message within your wider organisation, particularly with colleagues who use this service, to ensure they are aware of the change.

For further guidance go to Check a pension scheme member’s protected allowance and enhanced protection.

If you experience any issues viewing a member’s protections or enhancements, please email administrationpensions@hmrc.gov.uk with the subject line ‘LPE query’ and include the member’s full name, national insurance number, date of birth and PSA check reference (also referred to as the protection notification number).

Digitisation of relief at source (DigiRAS)

Reminder: use new deconsolidated relief at source references for April 2026 claims

Pension scheme administrators who historically grouped multiple schemes together under a single relief at source reference and have engaged with HMRC to obtain new deconsolidated relief at source references, are reminded that these must be used for each scheme from May 2026 when submitting claims relating to April 2026 and beyond. These changes form part of HMRC’s ongoing work to modernise and improve the administration of relief at source. Using the correct reference for each scheme is essential to ensure claims are processed accurately and without delay.

What you need to do

When you submit your first interim claim for the 2026 to 2027 tax year in May 2026, make sure you are using the new deconsolidated relief at source references when submitting claims. This applies to any relief at source interim or monthly claims submitted that covers a period in the 2026 to 2027 tax year onwards.

Why this matters

Using the correct relief at source references helps HMRC:

  • process claims efficiently
  • reduce errors and rework
  • ensure payments are issued correctly and on time
  • avoid having to reject claims submitted using any older consolidated references

It also helps pension scheme administrators avoid unnecessary follow up or resubmission of claims.

Further information

The process for submitting claims remains unchanged and you should continue to send HMRC forms APSS105 and APSS106 as usual but use the new relief at source references.

If you have a consolidated claim but have not yet heard from us, please email reliefatsource.administration@hmrc.gov.uk with ‘consolidated claim’ in the subject line.

Annual relief at source claims for consolidated relief at source references

Submission of annual claim (APSS106) for the 2025 to 2026 tax year

If you have previously submitted interim claims for multiple pension schemes, or intend to make an annual claim, using a consolidated relief at source reference number, then you should still submit your APSS106 using the consolidated relief at source reference number.

Relief at source returns

Annual return of information for 2025 to 2026 tax year

The deadline for submitting the 2025 to 2026 annual return of information is 5 July 2026. If you do not submit this on time, it may delay payment of:

  • interim claims for the tax month ending 5 July 2026
  • any claims for later months until we receive your annual return of information

You must make sure you submit the pension scheme administrator declaration: annual return of information.

This forms part of your return. Without it, your return will not be processed.

You can either:

  • send the APSS590 annual return of information declaration by post, or
  • email the APSS590 annual return of information to reliefatsource.administration@hmrc.gov.uk with ‘APSS590 Annual return of information declaration’ in the subject line

If you submit your annual return of information but it does not process, we will:

  • still consider this to be outstanding
  • stop any later interim repayment claims until we receive a resubmission

If on the third submission it still does not process, we will stop all future interim claims until we receive a further resubmission that is considered successful.

Completing and submitting the annual return of information

To make sure we can process your annual return of information, you must use the versions of the spreadsheet and electronic flat text file specifications that are currently on GOV.UK. Do not use a version that you’ve saved from a previous tax year.

If you’re submitting an annual return of information for the 2025 to 2026 tax year, you must use the:

It is important to make sure:

  • you use the correct naming convention when you submit your annual return via the Secure Data Exchange Service
  • the file name reference matches the sub reference included in the return

Details of how to name your files are in the relief at source spreadsheet and electronic flat text file specifications.

When you send in your annual return of information, make sure:

  • all fields are completed in the correct format
  • not to include unacceptable characters
  • you do not go over the maximum number of characters

The correct structured format for submitting data on your annual return of information can be found on ‘How to complete your annual return of information for pension schemes operating relief at source’.

It is important to submit your return in the correct format as:

  • your file may not process
  • your file could be rejected
  • it could mean you do not get a residency status report for your members

You can only submit your 2025 to 2026 annual return of information through the Secure Data Exchange Service (SDES).

Pension schemes migration to the Managing pension schemes service — action required

Since 2018, there have been two services operating for pension scheme administration: the new managing pension schemes service and the previous pension schemes online service. Since April 2022, we have been asking you to migrate your pension schemes to the managing pension schemes service.

Many pension scheme administrators have already migrated their schemes. To continue fulfilling your reporting obligations, you must take action now to ensure your schemes are prepared and migrated accordingly.

If you are a pension scheme administrator and have any pension schemes with a status of ‘open’ on the pensions schemes online service, you’ll need to enrol and migrate.

Enrolment Recovery

If you have not signed in for the last 3 years, you will not be able to access the service. You do not need to create a scheme administrator ID, you can recover your existing enrolment details to regain access.

To recover your details, go to section ‘how to recover your enrolment details in Manage a registered pension scheme. You will need to receive your activation code before you can continue the process of enrolling and migrating.

If your scheme is open you will need to complete 2 steps. This is covered in our YouTube video Enrolling and migrating to the Managing pension schemes service.

Step 1 — Enrolling on the managing pension schemes service

Enrolling onto the managing pension schemes service is not the same as migration. You must complete enrolment before you can migrate your schemes.

If you already have a Government Gateway account, sign in using the user ID and password that is linked to your scheme administrator ID. This service is not currently available via GOV.UK One Login.

Step 2 — Migrate your scheme to the managing pension schemes service

If you have already enrolled your ID, log on to the managing pension schemes service, and select ‘Add a pension scheme from the Pension Schemes Online service’.

Provide up to date information for the pension scheme to complete the migration process.

If you have already completed step one and enrolled, you can start the video at 2 minutes 40 seconds.

Winding up a scheme

If your pension scheme has wound up, you will need to report this through the event report on the relevant service.

If the wind up date is in the tax year 2022 to 23 and prior this must be reported through the pension schemes online service.

If the wind up date is in the tax year 2023 to 24 onwards the pension scheme will need to be migrated so you can report this through the event report on the managing pension schemes service

For more information on event reports please see the following guidance: Send pension scheme reports — GOV.UK.

Normal minimum pension age

Normal minimum pension age — transitional regulations

In Pension Schemes Newsletter 178 — February 2026, we explained that work is ongoing to develop the transitional regulations that will support the increase to the normal minimum pension age from age 55 to age 57 on 6 April 2028. While these regulations are still being prepared, we wanted to provide some early background about their intended scope and effect. All information provided here remains provisional and subject to change as the regulations are finalised ready for technical consultation. 

Changes to the normal minimum pension age can affect the continuation of certain pension benefit payments. When the normal minimum pension age was last increased in 2010 (from age 50 to 55), transitional arrangements were required to ensure affected members could continue to receive their benefits without interruption. Similar provisions will be necessary for the 2028 increase.

For example, a member who has already reached age 55 before 6 April 2028 may have met all the conditions to access a benefit before that date. However, after 6 April 2028, that same member may not be able to receive an authorised payment until they reach age 57. The aim of the transitional regulations is to ensure that members who have already become entitled to their pension benefits can continue to do so seamlessly.

These transitional provisions will only apply to members who have reached age 55 on or before 5 April 2028, and who would therefore have reached the existing normal minimum pension age at that time. Although legislation sets the minimum age at which benefits can be taken, this must always be considered alongside the rules of each pension scheme, which determine what benefits are available and from what age. In some cases, scheme rules may specify a higher minimum age than the normal minimum pension age.

Legislation for the 2028 increase already includes protection for members with an unqualified right to take their pension benefits before age 57, referred to as a protected pension age and this is reflected in existing guidance.

Further information on protected pension ages can be found in the Pensions Tax Manual:

Guidance on retaining a protected pension age after an individual transfer or a block transfer is also available in the Pensions Tax Manual:

The transitional regulations will apply to all registered pension schemes for UK tax purposes, including both defined contribution and defined benefit arrangements.

The normal minimum pension age framework does not apply to the State Pension, as it is not a registered pension scheme. Unregistered pension arrangements also fall outside the normal minimum pension age framework and are subject to separate tax rules.

Pension Payments

Where a member was aged 55 or 56 on 5 April 2028 and had already taken steps to access their pension benefits, such as designating funds for drawdown, applying those funds towards the purchase of an annuity, or becoming entitled to a scheme pension, those benefits can continue to be paid on or after 6 April 2028 as authorised payments. For these purposes, the member is treated as having reached age 57 immediately before their first post 6 April 2028 payment.

Example: pension payments start pre 6 April 2028

A member turns 55 in August 2027 and becomes entitled to a scheme pension, with the first instalment paid in December 2027, at a time when they are above the existing normal minimum pension age of 55. When the normal minimum pension age increases to 57 on 6 April 2028, the member is still only 55, and therefore below the new normal minimum pension age. However, the pension already in payment continues without interruption as an authorised payment, as pension rule 1 under section 165 FA 2004 has been satisfied.

If the same member wishes to start another pension on or after 6 April 2028, they will need to wait until they reach age 57 in August 2029, for it to be an authorised payment, unless a protected pension age or ill-health exception applies.

If a member wishes to crystallise further benefits after 5 April 2028, they must have reached the normal minimum pension age of 57 for those payments to be authorised.

Example: entitlement pre 6 April 2028, first pension payment made after 5 April 2028

A member designates funds into flexi-access drawdown on 30 June 2026 aged 55.  However, they do not take their first payment of drawdown pension until 2 May 2028 when they are aged 56. 

The transitional regulations will provide that the member is treated as having reached normal minimum pension age for the purposes of the payment of drawdown pension made from those pre 6 April 2028 designated funds. The drawdown pension payment will be an authorised payment.

The same principle will apply where the member became entitled to a scheme pension or lifetime annuity before 6 April 2028 having reached normal minimum pension age, but the first payment of scheme pension or annuity is not made until on or after that date.  

Guidance on when a member becomes entitled to various types of pension can be found in the Pensions Tax Manual at PTM0631310.

PTM061310 - Member benefits: essential principles: what is meant by ‘becoming entitled’ to pensions and lump sums — HMRC internal manual - GOV.UK

Pension Commencement Lump Sum  and Pension Commencement Excess Lump Sum

Where a member aged 55 or 56 on 5 April 2028 had already become entitled to a lump sum that would have qualified as a pension commencement lump sum or pension commencement excess lump sum had it been paid on or before that date, but no payment had been made, that lump sum can still be paid on or after 6 April 2028 as an authorised payment. In these cases, the member is treated as having reached age 57 immediately before the lump sum is paid.

Entitlement arises when all conditions under the scheme rules have been met such that the member has a right to receive the relevant pension benefit, rather than a mere expectation or intention. Further detail can be found in the Pensions Tax Manual:

Uncrystallised Funds Pension Lump Sums

An uncrystallised funds pension lump sum will only be an authorised member payment where it is paid after the member has reached normal minimum pension age. Accordingly, an uncrystallised funds pension lump sum paid on or after 6 April 2028 will only be an authorised member payment if the member has reached the new normal minimum pension age of 57 at the time the payment is made. Any uncrystallised funds pension lump sum payments made before that date which were authorised member payments at the time they were paid will remain authorised payments.

For example, a member reaches age 55 on 1 March 2027 and takes an uncrystallised funds pension lump sum on 1 June 2027. As the member had reached the normal minimum pension age of 55 at the time the payment was made, the uncrystallised funds pension lump sum is an authorised member payment. The member cannot take a further uncrystallised funds pension lump sum on or after 6 April 2028 until reaching the normal minimum pension age of 57.

Transfers of pensions in payments

The Registered Pension Schemes (Transfer of Sums and Assets) Regulation 2006 — SI 2006/499 make provision for when a pension in payment is transferred. Further detail can be found in the Pensions Tax Manual at:

Where a member who has started their pension having reached normal minimum pension age transfers their crystallised pension rights on or after 6 April 2027 whilst not yet aged 57, the replacement pension under the new pension scheme may be an authorised payment.  The existing provisions of SI 2006/499 provide that the new pension is treated as if it was the original (pre transfer) pension for the purposes of pension rule 1. 

Qualifying Recognised Overseas Pension Schemes (QROPS)

UK tax charges, such as the unauthorised payments charge, can apply to payments made from a QROPS.  These tax charges are known as the member payment charges.  Guidance on when the member payment charges apply can be found in the Pensions Tax Manual at:

For the purpose of the member payment charges, the transitional regulations will apply in broadly the same way to QROPS members aged 55 or 56 on 5 April 2028 as for members of registered pension schemes as outlined above. This ensures that individuals who became entitled to pension benefits before 6 April 2028 can continue to receive those payments as authorised payments after that date.

We will provide further details in a future edition of the pension schemes newsletter once the draft transitional regulations are ready for technical consultation.

Pension flexibility statistics

HMRC can now give more information on the number of tax repayment claim forms processed for pension flexibility payments.

From 1 January 2026 to 31 March 2026, we processed:

  • P55 — 9,291 forms
  • P53Z — 4,048 forms
  • P50Z — 603 forms

Total value repaid: £44,139,097.55.

The tax repayment figures for the period 1 April 2026 to 30 June 2026 will be published in Pensions schemes newsletter ― July 2026.

Registration Statistics

For 2025 to 2026, HMRC received in total 2,421 applications to register new pension schemes.

Of these schemes, 54% have been registered and we have refused registration for 33% of applications. No decision has been made on the remainder yet.