Guidance

Tax-free savings newsletter 18 — November 2025

Published 4 November 2025

1. Financial Conduct Authority rule change — cryptoasset Exchange Traded Notes

From 8 October 2025, changes were made to the Financial Conduct Authority rules to allow retail investors to access cryptoasset Exchange Traded Notes on the Financial Conduct Authority website. These products, previously restricted to professional investors, will be available to individuals in the UK through Financial Conduct Authority recognised investment exchanges.

This means that from 8 October 2025 cryptoasset Exchange Traded Notes are automatically eligible as qualifying investments for:

• registered pension schemes
• stocks and shares Individual Savings Accounts (ISA)

The government has confirmed that, with effect from 6 April 2026, cryptoasset Exchange Traded Notes will be reclassified as qualifying investments for Innovative Finance ISAs only.

The ISA legislation will be amended to tell users that any cryptoasset Exchange Traded Notes included in stocks and shares ISAs before 6 April 2026, will be treated as qualifying Innovative Finance ISA investments from that date.

From 6 April 2026, cryptoasset Exchange Traded Notes may only be held in an Innovative Finance ISA. Where the ISA manager is not approved to offer the Innovative Finance component they must either be:

• removed from stocks and shares ISA
• liquidated

ISA managers must have the approval from HMRC to offer the Innovative Finance component. Find out how to apply for the relevant approval.

Amending the ISA regulations requires industry engagement, and compliance with Parliamentary procedure. While this cannot coincide with the Financial Conduct Authority changes, HMRC is working at pace to introduce the changes by April 2026. This timeline will give ISA managers and investors time to engage and then prepare for the change. ISA managers’ guidance will be updated accordingly.

Inclusion of cryptoasset Exchange Traded Notes in the Innovative Finance ISA reflects the government’s commitment to ensuring that UK savers can access a diverse range of assets within tax-advantaged wrappers, while recognising the evolving nature of digital finance. It marks a significant step in supporting investor access to emerging asset classes and embracing the future of digital finance. Innovative Finance ISAs are a first step and allowing cryptoasset Exchange Traded Notes in all stocks and shares ISA’s is something we will keep under review as the market matures and consumer understanding grows.

The full policy statement for tax treatment of cryptoasset Exchange Traded Notes was published on 8 October 2025.

2. ISA reporting service — update

We previously told you in Tax-free savings newsletter 11 (March 2024) that HMRC will be working with ISA managers to deliver digitalisation of ISA reporting following the Government announcement at Autumn Statement 2023.

In Tax-free savings newsletter 14 (October 2024) we informed you how to sign up to collaboration forums to engage with HMRC on digitalisation of ISA reporting. In the following information we have shared some of the key design decisions that have been made to date and have been discussed during collaboration forums. 

2.1 National Insurance Number requirements — reinforcing data accuracy 

We recognise that the requirement for ISA subscriptions to have a National Insurance Number from April 2027 represents a new administrative step for some ISA managers. However, this is a critical component of the digitalisation of ISA reporting model.

Accurate personal identifiers are essential for effective data matching and enforcement of ISA limits. While we understand concerns about outdated records and low response rates to outreach, we remain committed to working collaboratively with industry to make this process as efficient as possible.

Some stakeholders suggested applying stricter National Insurance Number requirements only to new accounts. After careful consideration, we concluded that consistent identity verification is necessary for all account holders, to ensure robust oversight of ISA limits.

2.2 Application programming interface schema release update

We were aiming to publish the application programming interface schema in August 2025. However, due to ongoing refinements to digitalisation of ISA reporting and the associated technical specification, publication has been delayed. We now expect to release the application programming interface schema later this month.

We understand the pressure that implementation timelines can place on technical teams. However, we have been listening to user feedback and considering how emerging requirements can be factored into the proposed solution to ensure we build a service that is as inclusive as possible.

We are resolving outstanding technical detail to make sure the schema and supporting specification are robust. We understand how frustrating this delay is for you and recognise you then need time for amendments to be made to your systems, but it is important we get it right. After the release, we will be arranging sessions for a walk-through and any questions.

2.3 Cumulative model confirmed as preferred approach  

Following a comprehensive design review, we have confirmed that the cumulative model will be used to monitor the £20,000 annual ISA subscription limit.

Under this model, each investor will be reported on a single line, showing the year-to-date total subscribed to each account, as follows:

• subscriptions should be added to the previous month’s cumulative total
• withdrawals that reduce the eligible subscription amount should be subtracted from the previous month’s cumulative total
• adjustments should be made to reflect current year subscriptions that have been transferred in or out
• corrections should be applied where an oversubscription has occurred, and a repair is required

Alongside the cumulative amount, the date of the last subscription event in the account will also be reported. This date will be used to help identify cases where an investor may have oversubscribed across their ISA.

In scenarios where the account is a flexible ISA and there is a net withdrawal in a given month (the cumulative amount is lower than the previous month), but the last subscription date is the most recent, our IT system will recognise this and make sure that the withdrawal does not trigger an oversubscription alert.

This approach enables accurate tracking of subscriptions and withdrawals throughout the year.

While a transactional (event-based) model was considered, it introduced significant complexity in both implementation and ongoing operations. The cumulative model provides a more streamlined and efficient solution, supporting our aim to reduce compliance risk without overengineering the system.

To ensure consistency, the digitalisation of ISA reporting regulations will be aligned with the cumulative model, and we expect to publish these alongside the application programming interface schema.

3. ISA reporting service — user research

Over the next few months, we are running user research sessions (between 1 and 1.5 hours using Microsoft Teams) to help improve how ISA reports are submitted to HMRC.

User research helps us understand how people use a service, what works well, and what causes problems. Your feedback will help us design a better reporting process.

We would like to hear from:

• organisations planning to use an application programming interface for monthly reporting
• the person responsible for submitting monthly reports, either in ISA Manager organisations or in third-party administrator organisations (those who submit on behalf of ISA Managers)

The sessions will focus on:

• looking at ideas of how the new monthly reporting process could work
• looking at HMRC’s service guide for using the application programming interface for monthly reporting and what this process could look like

The sessions will not cover:

• application programming interface specifications or schemas
• data items
• detailed reporting requirements

Your feedback will help shape the future of the reporting service.

If you’d like to take part, email: enquiries.savings@hmrc.gov.uk and put ‘user research’ in the subject line.