Guidance

Newsletter 176 — December 2025

Published 18 December 2025

Transfers to qualifying recognised overseas pension scheme (QROPS)

Launch of a new reporting function on the Managing pension schemes service

You can now report a transfer to a qualifying recognised overseas pension scheme on the Managing pension schemes service. This replaces the print and post form, APSS262.

The Managing pension schemes service allows you to quickly and easily self-serve.

You can compile, save and submit your QROPS transfer report on the service. While being compiled, the report will stay on the service for 28 days (since last accessed) until you’ve completed the declaration and submitted it. If you do not access a compiled report within 28 days, it will be automatically deleted. If deleted, you will have to start the report again.

You must submit your report to HMRC within 60 days of the date of the transfer.

Once you have successfully submitted your QROPS transfer report, you’ll see a confirmation screen on the service. This will include a unique QROPS transfer (QT) reference allocated to the individual member’s transfer.

You’ll be able to make amendments to a QROPS transfer report that you’ve submitted. This will save as a new version of the report on the scheme record. You’ll only ever be able to amend the latest version you submitted.

Future enhancements

In early 2026 we will enhance this feature to include:

• searching for a QROPS transfer report on the Managing pension schemes service
• email confirmation upon successful submission

We will tell you in future newsletters when these enhancements are released.

Migrate your pension scheme to the Managing pension schemes service

If your pension scheme has a Pension Scheme Tax Reference (PSTR) beginning with 0, and you have not already done so, you will need to migrate the pension scheme to the Managing pension schemes service to be able to compile and submit a QROPS transfer report.

Watch a video about enrolling and migrating to the Managing pension schemes service on YouTube. You will find out about how to:

• enrol your scheme administrator ID onto the service
• register a new pension scheme and manage the schemes you are administrator for
• migrate your open pension schemes onto the service

Read further guidance on migrating your pension schemes to the Managing pension schemes service.

If you are having issues with migrating a pension scheme, you should email migration.mps@hmrc.gov.uk using ‘Managing pension schemes — Migrating pension schemes’ in the subject line.

Protections and enhancements — members protections and enhancements

In pension schemes newsletter 171, we told you the protection look up service will be moving onto the Managing pension schemes service.

The new authenticated look up service, called ‘Check a pension scheme member’s protections and enhancements’ will go live in early 2026. To use the look up service you will need your member’s:

• full name
• date of birth
• National Insurance number
• pension scheme administrator check reference

How to access ‘Check a pension scheme member’s protections and enhancements’

To access the Managing pension schemes service, you must be registered as either a:

• pension scheme administrator
• pension scheme practitioner

If you have colleagues who only need to check protections and enhancements, they should register themselves as pension scheme practitioners. 

To view the authenticated look up service, sign into the Managing pension schemes service and use the ‘Check a pension scheme member’s protections and enhancements’ link on the account dashboard. 

How you can help us

We are inviting volunteers to use the new version of the authenticated look up service.

If you would like to take part, email manraj.padam@digital.hmrc.gov.uk using ‘Private Beta Research’ in the subject header.

Further guidance available

Find out how to register as a pension scheme administrator.

Find out about the pension scheme practitioner role.

Public service pensions remedy — offsetting unauthorised payments

We told you about the process of offsetting unauthorised payments and what to report to HMRC in both:

• public service pensions remedy newsletter — September 2024
• public service pensions remedy newsletter — June 2025

We have been in contact with pension schemes that were likely to be affected by this process to provide both guidance and a template spreadsheet. This template is for scheme administrators or authorised practitioners to complete when reporting any members that schemes have used the offsetting process for.

Following on from this, we have also published guidance on offsetting unauthorised payments for chapter 1 members.

When you report any offsetting of unauthorised payments, for it to be accepted as a submission:

• use the template provided by HMRC, without making any formatting changes to any of the fields
• complete all the mandatory fields, along with the declaration

If you provide a template with missing or incorrect information this will result in a rejection, penalties, or both. If you need a copy of the most up to date version of the template, contact your single point of contact.

Mandatory tax adviser registration

HMRC has introduced a new requirement in Part 7 of Finance (No.2) Bill for all tax advisers who interact with HMRC on behalf of clients to register and meet minimum standards.

This is an important step towards raising standards and reducing poor practice, helping to create a fairer market for taxpayers and advisers, for all tax advisers who interact with HMRC on behalf of clients to register and meet minimum standards.

Registration is required where entities:

• provide tax advice
• interact with HMRC in relation to the clients’ tax affairs

The provision of information to clients or members (for example, providing information about Annual Allowance charges or holding pre-retirement information sessions) is not caught by the requirement to register, as there is no interaction with HMRC about the clients’ tax affairs.

The legislation includes an exemption from the requirement to register for interactions with HMRC which are mandated under legislation. This responds to feedback from the pensions industry that earlier draft legislation could bring pension scheme administrators and practitioners into scope through entities responding to a range of mandatory reporting requirements.

The legislation will exempt entities from the requirement to register where interactions with HMRC are carried out in response to requirements under legislation, for example:

• pension scheme administrators
• pensions practitioners
• scheme managers of qualifying overseas pension schemes
• qualifying recognised overseas pension schemes
• responsible persons for employer-financed retirement benefit schemes

Interactions which are not caught by this exemption and see tax advice provided to clients and an interaction with HMRC would require registration with HMRC.

Relief at source (RAS) — residency status reports

Notification of residency status report for tax year 2024 to 2025

Scheme administrators of a Relief at source pension scheme should now have successfully submitted their annual return of information for tax year 2024 to 2025.

If you have not successfully submitted your annual return of information for tax year 2024 to 2025, we will not be able to provide you with a residency report in January 2026. However, it’s still important that you submit your annual return for tax year 2024 to 2025 as soon as possible, otherwise we may stop your subsequent interim repayment claims.

Receiving your notification of residency status report

If you’ve successfully submitted your annual return of information for tax year 2024 to 2025, in January 2026, we’ll tell you the residency tax status of your scheme members, so that you can apply the correct rate of relief at source to your scheme members in the tax year 2026 to 2027.

From mid-January 2026, you’ll be able to download your notification of residency status report from the Secure Data Exchange Service (SDES). Your report will be based on data from your 2024 to 2025 annual return of information.

We’ll send you an email when we start to release the notification of residency status reports. If you want to be added to our mailing list, email reliefatsource.administration@hmrc.gov.uk, using ‘Relief at source — mailing list’ in the subject line.

You’ll also receive an email through the SDES when your file is available for you to download. You’ll have 6 days (144 hours) to download this, starting from when we make the file available to you.

You should check that your email address is up to date on the SDES. If it’s not up to date, you should update your email address to avoid any delay in accessing your report. If you’re expecting an email from us but do not think you’ve received one, check your junk folder in your email account.

If you do not receive a notification of residency status report

If you do not receive a residency report in January 2026, you can check your member’s residency status for relief at source by using our look up service. You can check the residency tax status for single or multiple members, or default to the UK basic rate for your members.

If you do not have a residency status for a member by the time you claim relief at source on their first contribution in a tax year, you must treat them as having a ‘rest of UK’ residency status. You must not apply a tax rate based on the member’s address.

Once you’ve used a residency status to claim relief at source for a member, you must use this for the whole of the tax year.

In a future newsletter we’ll provide further guidance on what you’ll need to do if:

• you do not receive your report
• there are issues with your report

Pension scheme return — submission deadline reminder

From tax year 2024 to 2025 onwards, returns must be submitted through the Managing pension schemes service.

If you have not yet migrated your pension schemes to the Managing pension schemes service, you need to do so now.

Watch a short YouTube video explaining how to enrol and migrate your pension schemes to the Managing pension schemes service.

Who needs to complete a pension scheme return

You’ll only need to submit a pension scheme return if we have issued a notice to file. Even if you have not previously received a notice to file a pension scheme return, you may in the future.

If you’re an administrator for more than one scheme, you may now have to complete a return for each scheme you manage.

Deadline for submitting a pension scheme return

You must submit your pension scheme return for each tax year by 31 January after the end of the tax year. If it’s not received by the deadline, you’ll be charged a £100 penalty.

Daily penalties of up to £60 a day may also be charged.

For tax year 2024 to 2025, if you migrated your scheme before 31 October 2025, your pension scheme return must be submitted by 31 January 2026.

If you migrated your scheme after 31 October 2025, notices to file for tax year 2024 to 2025 will have a filing deadline of 3 months from the date of issue.

Read about submitting a pension scheme return using the Managing pension schemes service.

Event reporting

The deadline for submitting an event report for tax year 2024 to 2025 is 31 January 2026.

In pension schemes newsletter 148 — March 2023, we told you that event reports for tax years 2023 to 2024 onwards can only be submitted on the Managing pension schemes service. You can only submit your event report once the tax year has ended, unless:

• you’re reporting that the pension scheme has wound up
• it has become or ceased to be a master trust

If your pension scheme has a Pension Scheme Tax Reference (PSTR) beginning with 0, and you have not already done so, you will need to migrate the pension scheme to the Managing pension schemes service before you can submit an event report. 

Watch a short video on YouTube explaining how to enrol and migrate to the Managing pension schemes service.