HM Revenue and Customs (HMRC) set requirements on scheme administrators, insurance companies, members and employers to give information.
The notification of registration issued by HMRC is the scheme’s confirmation that it’s a registered pension scheme. You must keep this as you may need to produce this letter at a later date – for example to prove that the scheme is formally registered.
As a scheme administrator, scheme employer, trustee or provider of administrative services to a registered pension scheme you must also keep documents for 6 years that relate to:
- money received into the scheme
- money owed to the scheme
- investments or assets held by the scheme
- payments made by the scheme
- contracts to purchase an annuity in respect of a member of the scheme
- the management of the scheme
- any transfer out of the scheme
Information required by HMRC
As a scheme administrator of a registered pension scheme you must automatically provide HMRC with:
- Event Reports
- Accounting for Tax (AFT) Returns
- unauthorised borrowing reports
- notification of a transfer of pension funds to a qualifying recognised overseas pension scheme (QROPS)
- notification that you’re no longer the scheme administrator
There are some events that occur in a registered pension scheme that must be reported to HMRC using an Event Report. You must send Event Reports to HMRC using the Pension Schemes Online Service no later than 31 January after the end of the relevant tax year.
If you’re reporting the winding up of the pension scheme the deadline date is 3 months from the date the scheme finishes winding up.
The scheme administrator is subject to tax charges when their registered pension scheme makes certain payments. Most of these tax charges must be reported and paid to HMRC using the AFT Return. This is a quarterly return that must be sent to HMRC together with the tax due.
Relief at source annual information return
Registered pension schemes operating relief at source must submit an annual information return detailing all member contributions paid in the previous tax year.
Read more about relief at source annual information return.
Unauthorised borrowing report
As scheme administrator you must report any borrowing by the registered pension scheme that doesn’t meet the authorised borrowing conditions to HMRC. You must do this using form APSS303 by 31 January following the end of the tax year in which the scheme borrowed the money.
Report of transfer of pension funds to a qualifying recognised overseas pension scheme (QROPS)
Scheme administrators must check the scheme they are making a transfer to is a QROPS. Any transfer to an overseas scheme that isn’t a QROPS will result in the scheme sanction charge for an unauthorised payment.
Scheme adminstrators must ask a member requesting an overseas transfer, within 30 days of receiving the request, for information about the overseas scheme. The member can use form APSS 263 to supply this information.
The scheme administrator must check whether the requested transfer is a taxable overseas transfer and subject to the 25% tax charge on qualifying transfers.
Transfers made before the member requesting it supplies the information to the scheme administrator will be subject to the overseas charge. This can be reclaimed by the scheme administrator if it turns out the charge shouldn’t have applied.
They must tell HMRC within 60 days of a transfer by submitting form APSS262.
The scheme administrator will have to pay any tax due to HMRC and account for it on the AFT Return
If a repayment is due in relation to a tax charge they pay, the scheme administrator will need to make a claim within 5 full tax years of the original transfer using form APSS242. HMRC will review the claim before making any repayment and contact the scheme administrator to request an amended AFT return.
Once HMRC has made a repayment to the scheme administrator, the scheme administrator must:
- provide the member with the details of the:
- amount of the repayment
- reason for the repayment
- date it was repaid
- provide the scheme manager with a copy of the previous notification of the original transfer together with:
- details of the amount of the repayment
- the reason for the repayment
- the date it was repaid
Reporting that you’re no longer the scheme administrator
You must tell HMRC if you stop being the scheme administrator within 30 days of the date you stopped, using the Pension Schemes Online Service.
Pension Scheme Return (PSR)
HMRC may send a notice to file letter to the scheme administrator telling them to complete a PSR. They must complete and submit the PSR by the date shown on the letter.
Pension flexibility payments and pension flexibility death benefits payments
You must report pension flexibility payments and pension flexibility death benefits payments to HMRC through Real Time Information (RTI).
You can read more about this in chapter 2 of the CWG2 guide.
Tax return for trustees of registered pension schemes
HMRC will send the pension scheme trustees a notice to file a SA970 tax return if they’ve reclaimed tax deducted from investment income. The scheme trustees must also complete this tax return if they have any taxable income. This return is only available in paper format and must be submitted by 31 January following the end of the relevant tax year.
Keeping your information up to date
You should tell HMRC about any changes to the scheme details or the scheme administrator. You can do this using the Pension Schemes Online Service or by submitting a paper form.
If you need to amend the establisher name for a scheme that has a status of open or if you wish to amend the scheme name you’ll need to notify HMRC in writing at:
Pension Schemes Services
HM Revenue and Customs
You’ll need to include the:
- PSTR of scheme you want to make changes to
- current name of scheme or establisher
- new name of scheme or establisher
- reason for change
- contact name, address and telephone number
- copy of new trust deed
Changes of scheme administrator/practitioner details are reported on form APSS153.
Information that must be given to members
As a scheme administrator you must give certain information to members:
- a flexible access statement telling them they have flexibly accessed their money purchase pension savings and information about what they need to do next – if they’re accessing those pension rights for the first time
- a standard pension savings statement of the amount of their pension savings in the pension scheme for a tax year – if they’re more than the annual allowance or the member asks for a statement
- a money purchase pension savings statement where they’ve flexibly-accessed their money purchase pension rights, and their subsequent money purchase pension savings exceed the available money purchase annual allowance
- a lifetime allowance statement telling them how much of the lifetime allowance they’ve used up when their pension pot was tested against the lifetime allowance
- details of:
- the amount of tax due if they’re subject to the lifetime allowance charge
- any unauthorised payment caused by the scheme providing the member with a benefit in kind
- transfers to a QROPS including any tax paid or the exemption which made it tax-free
If the overseas transfer charge is repaid by HMRC, you must tell the member, within 3 months of the repayment, the date and amount of the repayment and the condition which allowed it
Find more about the events resulting in a member accessing their money purchase pension rights.
Giving information to other scheme administrators and insurers
If a member transfers a pension in payment to another pension scheme the transferring scheme administrator must give the new scheme administrator details of the amount of lifetime allowance used up when that pension first started. They must do this within 3 months of the transfer.
If the transferring scheme administrator believes the member first flexibly accessed their money purchase pension rights before the transfer, they must tell the new scheme administrator the date they believe it happened. They must do this within 31 days from the day the transfer took place or the day they first became aware that the member had flexibly accessed pension rights, whichever is later.
A scheme administrator must give information to an insurance company if:
- a member or scheme administrator has purchased an annuity using scheme funds
- a member receiving a drawdown pension uses part of their drawdown pension fund to buy an annuity from an insurance company
They must give details of the amount of lifetime allowance used up by the pension (and any tax free lump sum) when the pension first started. They must do this within 3 months of the purchase of the annuity.
Giving information to QROPS scheme managers
Where a scheme manager has made a transfer to a QROPS, the scheme administrator needs to inform the QROPS scheme manager within 31 days of the transfer:
- whether a 25% tax charge applies to the transfer
- how much tax has been paid
- if the charge didn’t apply, why it was tax-free
Information that must be given to and by legal personal representatives
As scheme administrator you must tell the member’s personal representative if the scheme pays a lump sum death benefit that is tested against the lifetime allowance.
If asked, a scheme administrator or insurance company must give information to a legal personal representative about the amount of lifetime allowance used up by a pension or lump sum payment within 2 months of a request.
If the member’s total pension savings are more than the lifetime allowance the member’s personal representative must tell HMRC.
Trustees of a trust receiving a lump sum death benefit
As a scheme administrator, if you pay taxable lump sum death benefits to the trust, you must tell the trustees:
- the amount of the payment before tax
- how much tax you deducted
You must tell the trustees this information within 30 days of paying the lump sum death benefit to the trust.
The trustees will pass this information to any beneficiary who receives a trust payment funded by the lump sum death benefit the trust received from the pension scheme.
Further guidance and the Pensions Tax Manual
A number of guides on pension scheme administration are available on GOV.UK and full detailed technical guidance regarding registered pension schemes can be found in the Pensions Tax Manual.