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HMRC internal manual

Pensions Tax Manual

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HM Revenue & Customs
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Information and administration: the event report: essential principles

Glossary PTM000001
   

 

What is the Event Report?
Reportable fund movements
Reportable changes
Submitting the Event Report
When the Event Report must be submitted
What happens if the Event Report is late or inaccurate
How the Event Report must be submitted

 

Section 251 Finance Act 2004

Regulation 3 The Registered Pension Schemes (Provision of Information) Regulations 2006- SI 2006/567

What is the Event Report?

The scheme administrator of a registered pension scheme must tell HMRC when certain reportable events occur. This is done by submitting the Event Report for a tax year.

These reportable events are split into two categories:

  • reportable changes, and
  • reportable fund movements.

The number of reportable events has changed over time as has the definition of what has to be reported. The table below shows which reportable events apply for which tax year.

 

Reportable event 2011-12 2012-13 & 2013-14 2014-15 2015-16 onwards
         
1 Yes Yes Yes Yes
2 Yes Yes Yes Yes
3 Yes Yes Yes Yes
4 Yes Yes Yes Yes
5 Yes Yes Yes Yes
6 Yes Yes Yes Yes
7 Yes Yes Yes Yes
8 Yes Yes Yes Yes
8A Yes Yes Yes Yes
9 Yes Yes Yes Yes
10 Yes Yes Yes Yes
11 Yes Yes Yes Yes
12 Yes Yes Yes Yes
13 Yes Yes Yes Yes
14 Yes Yes Yes Yes
15 No No No No
16 No No No No
17 No No No No
18 Yes Yes Yes Yes
19 Yes Yes Yes Yes
20 Yes Yes Yes Yes
21 No Yes Yes No
22 No No Yes Yes
23 No No No Yes

 

 

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Reportable fund movements

Reportable fund movements relate to payments made by a registered pension scheme and the reportable events that fall into this category are:

1: Unauthorised payments

2: Payments exceeding 50 per cent of the standard lifetime allowance

3: Early provision of benefits

4: Serious ill-health lump sum

5: Cessation of ill-health pension

6: Benefit crystallisation events and enhanced lifetime allowance, enhanced protection, fixed protection, fixed protection 2014, fixed protection 2016, individual protection 2014 or individual protection 2016

7: Pension commencement lump sum

8: Pension commencement lump sum: primary and enhanced protection

8A: Stand-alone lump sum

9: Transfers to qualifying recognised overseas pension schemes

15: Alternatively secured pension (up to 2010-11)

16: Transfer lump sum death benefit (up to 2007-08)

17: Lump sum payment after the death of a member aged 75 or over (up to 2010-11)

18: Scheme chargeable payment

21: Flexible drawdown arrangements (up to 14-15)

22: Annual Allowance

23: Dual annual allowances.

Scheme administrators do not need to report an event relating to a member who was not a relevant UK individual whilst they were an active member of the registered pension scheme. Guidance on reportable fund movements can be found at

Guidance on reportable events for tax years before 2011-12 can be found in an archived version of the Registered Pension Scheme Manual held on the National Archives website.

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Reportable changes

Reportable changes are events that relate to changes in the details about the registered pension scheme. The reportable events that fall into this category are:

The completion of winding up of the pension scheme (PTM168000), and

10: Investment-regulated pension scheme

11: Changes in scheme rules

12: Changes to rules of a scheme treated as more than one scheme pre A-day

13: Change in legal structure of scheme

14: Change in number of members

19: Country or territory of establishment

20: Occupational pension Scheme.

Guidance on reportable changes can be found at PTM161700.

Guidance on reportable events for tax years before 2011-12 can be found in an archived version of RPSM held on the National Archives website.

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Submitting the Event Report

Regulation 3(1) The Registered Pension Schemes (Provision of Information) Regulations 2006- SI 2006/567

The scheme administrator is responsible for filing the Event Report and ensuring it is accurate and complete. Where a scheme has been de-registered then the person(s) who was the scheme administrator immediately before the scheme was de-registered is responsible for filing the Event Report.

A practitioner can file the Event Report on behalf of the scheme administrator but the scheme administrator remains responsible for ensuring that it is submitted on time and the contents are correct. Where a practitioner submits the report the scheme administrator should have seen and approved the content of the Event Report before it is submitted to HMRC. The practitioner must make a declaration that the scheme administrator has approved the contents before they can submit it to HMRC.

The scheme administrator is liable for penalties if the Event Report is incomplete or inaccurate, including where they ask a practitioner to submit the report on their behalf.

The Registered Pension Schemes (Splitting of Schemes) Regulations 2006 - SI 2006/569

Where the registered pension scheme is a split scheme the sub-scheme administrator is responsible for filing the Event Report due for their sub-scheme. The Registered Pension Schemes (Splitting of Schemes) Regulations 2006 specifies which schemes are split schemes, how they are split into sub-schemes and who the sub- scheme administrator is.

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When the Event Report must be submitted

HMRC will not send a notice telling the scheme administrators that an Event Report needs to be submitted. If a pension scheme is registered and a reportable event has occurred in the tax year an Event Report must be submitted. If no reportable events have occurred in the tax year the scheme administrator does not need to send in an Event Report.

HMRC must receive the Event Report by 31 January after the end of the tax year to which the Event Report relates. Unless the registered pension scheme has wound up the Event Report cannot be filed before the end of the tax year.

If the Event Report is for the tax year ended 5 April 2014 the Event Report can be filed in the period 6 April 2014 to 31 January 2015. Where an Event Report is submitted late penalties may apply.

If a registered pension scheme has wound up, the deadline for filing the Event Report becomes three months after the scheme completed winding up. So if a scheme had events to report for the 2013-14 tax year, and the scheme wound up on 1 June 2014, the 2013-14 Event Report should be filed by 31 August 2014. An Event Report for 2014-15 (to cover the scheme wind up) will also need to be filed by 31 August 2014.

There is a different deadline for reporting transfers to a qualifying recognised overseas pension scheme that were requested by the member after 5 April 2012. The deadline for these reports is 60 days following the date of the transfer.

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What happens if the Event Report is late or inaccurate

Section 98 Taxes Management Act 1970

If the Event Report is not filed on time the scheme administrator will be liable to a penalty, currently up to £300. Further penalties may be due where the Event Report still hasn’t been sent in after this penalty has been raised. The further penalty can currently be up to £60 for every day that the Event Report is late. As soon as the Event Report is correctly filed no more extra daily penalties can be raised.

If the information in the Event Report is not correct the scheme administrator can be liable to a penalty for fraudulently or negligently making an incorrect return. This penalty can currently be up to £3,000.

Scheme administrators can appeal against a penalty using form APSS 413.

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How the Event Report must be submitted

Regulations 4 and 6 The Registered Pension Schemes and Overseas Pension Schemes (Electronic Communication of Returns and Information) Regulations 2006 - SI 2006/570

With the exception of reports under event 9 (transfer to a qualifying recognised overseas pension scheme) for transfers requested after 5 April 2012, the Event Report must be delivered electronically using Pension Schemes Online. The scheme administrator will not have met their obligation to file an Event Report until submission has been accepted by Pension Schemes Online. The legislation treats any paper Event Reports as not having been delivered.

There is a different process for reporting transfers to a qualifying recognised overseas pension scheme, where the transfer was requested after 5 April 2012. These transfers must be reported using form APSS 262 - Transferring UK tax-relieved pension assets - within 60 days of the transfer.

You can only submit one Event Report per scheme per year. The Guide to using the Online Service for scheme administrators and practitioners (gov.uk website) sets out the practical steps of filing an Event Report.

It is possible to compile the Event Report throughout the year and save it. However HMRC cannot see the content of an Event Report that has been compiled and saved, but not submitted. The Event Report must be submitted to meet the scheme administrator’s filing obligations. Just compiling, but not submitting an Event Report does not meet the obligation to file.

Once you have submitted the Event Report any changes you want to make to it will be an amendment. You can amend an Event Report using Pension Schemes Online after it has been submitted. You will need to wait for 24 hours after the Event Report has been submitted before you can make amendments to that Event Report.

You can report an amendment to a submitted Event Report by paper. There are set forms for this purpose; these are:

  • APSS 300B for amendments for tax years Event Report for 2008-09 and subsequent years
  • APSS 300A for amendments for tax years 2006-07 and 2007-08.

These forms can be downloaded from the gov.uk website.

If the form is not completed correctly, signed and dated HMRC will return the form to the scheme administrator. If this is done no amendment will be made to the Event Report. The scheme administrator will need to either:

  • send a correctly completed form APSS 300A/B, or
  • amend the Event Report using Pension Schemes Online.