Guidance: Information requirements for pension schemes

Records you must keep

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 your certificate 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
• annual return of information (if you’re the scheme administrator of a relief at source scheme)
• unauthorised borrowing reports
• notification of a transfer of pension funds to a qualifying recognised overseas pension scheme (QROPS)
• if your scheme becomes or ceases to be a Master Trust scheme
• notification that you’re no longer the scheme administrator

Event reports

There are some events that occur in a registered pension scheme that you must report to HMRC using an event report. You must send event reports to HMRC no later than 31 January after the end of the relevant tax year.

If you are reporting the winding up of the pension scheme the deadline date is 3 months from the date the scheme finishes winding up.

AFT Return

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 return of information

Registered pension schemes operating relief at source must submit an annual return of information detailing all net contributions paid in the previous tax year. As part of the return, you must also complete and send us the APSS590 confirming that the information on the return is true and complete. You must submit this return by 5 July following the end of the tax year in which the contributions were made.

Read more about relief at source annual information return and the declaration.

Unauthorised borrowing report

As scheme administrator you must report any borrowing by the registered pension scheme that does not 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 QROPS

You 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 APSS263 to supply this information.

You 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 supplies the information to the scheme administrator will be subject to the overseas charge. You can reclaim this if it turns out the charge should not have applied.

You must tell HMRC within 60 days of a transfer by submitting form APSS262.

You 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, you 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 you to request an amended AFT Return.

Once HMRC has made a repayment, you must provide the member with details of the:

• amount of the repayment
• reason for the repayment
• date it was repaid

You must also 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

Report if you become or stop being a Master Trust

A Master Trust scheme is an occupational pension scheme which provides money purchase benefits, either alone or in conjunction with other benefits. The scheme must be used, or intended to be used, by two or more employers but the:

• employers cannot be connected, such as part of the same group of companies
• scheme cannot be a relevant public service pension scheme

You must tell HMRC if your scheme becomes or ceases to be a Master Trust. You must make this report using form APSS578 rather than on the event report.

You also need to tell The Pensions Regulator if you become or cease to be a Master Trust.

If you become a Master Trust you must also apply to The Pensions Regulator for authorisation. If you do not get authorisation from The Pensions Regulator, you will not be able to operate as a Master Trust.

If you cease to be a Master Trust, you may also need to tell The Pensions Regulator. You can find more information on reporting events on The Pensions Regulator website.

Report that you are no longer the scheme administrator

You must tell HMRC if you stop being the scheme administrator of a scheme within 30 days of the date you stopped. You can do this online.

If your scheme has a PSTR beginning with ‘2’, you should do this on the Managing pension schemes service. If you have stopped being a scheme administrator for all schemes, you can de-enrol as a scheme administrator on the Managing pension schemes service.

If your scheme has a PSTR beginning ‘0’, you should do this 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 have 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.

Keep your information up to date

You should tell HMRC about any changes to the scheme details or the scheme administrator.

Tell us your scheme administrator details have changed

If your scheme has a PSTR beginning with ‘2’, you should tell us about changes to your scheme administrator details using the Managing pension schemes service. If you’ve stopped being a scheme administrator for all schemes, you can de-enrol as a scheme administrator on the Managing pension schemes service.

If your scheme has a PSTR beginning ‘0’, you should report changes to your scheme administrator details through the Pension Schemes Online service. Find out more in the Pension schemes online user guide.

Tell us your scheme details have changed

If your scheme has a PSTR beginning with ‘2’ you must tell us about changes to your scheme details using the Managing pension schemes service.

If your scheme has a PSTR beginning with ‘0’, you must tell us about changes to your scheme details using the Pension Schemes Online service. If your pension scheme has migrated, you’ll need to update the details on both services.

If you need to amend the scheme name you’ll need to tell HMRC in writing at:

You’ll need to include the:

• PSTR of the scheme you want to make changes to
• current name of scheme
• new name of scheme
• reason for change
• contact name, address and telephone number
• copy of new trust deed

Information that must be given to members

As a scheme administrator you must give certain information to members, such as:

• 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 are 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 are more than the annual allowance or the member asks for a statement
• a money purchase pension savings statement where they have 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 have used up when their pension pot was tested against the lifetime allowance
• 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.

Relief at source member information playback

Before your member can make contributions under relief at source, and before you can claim tax relief from HMRC, the member or their representative must:

• provide basic personal information
• make certain declarations

If these are not given in writing or are provided by someone other than the member or their representative, you must replay all the information back to the member and make a declaration on their behalf. This is referred to as playback.

The scheme administrator’s playback declaration

To carry out a playback you must provide the member with:

• a copy of the declaration you made on their behalf, in writing or as an electronic communication with your electronic signature (as scheme administrator)
• all the basic personal information that was given to you, as set out in PTM044220 Information requirements before claiming relief at source

When you do this you must also state the terms of the declarations that have been made.

Review of playback information by the member

You must give your member 30 days to review the information you send them to make sure it’s correct. Your playback declaration takes effect from the date you sent it if within the 30 days the member does not:

• ask you to make corrections
• tell you that they no longer wish to become a member

If your member tells you that the information needs correcting you should send a new, revised playback declaration.

If your member told you that your original playback declaration was incorrect within 30 days, and they do not tell you that the new revised playback declaration is incorrect within 30 days from when you sent the revision, your new revised playback declaration takes effect from the date you sent your original playback declaration.

Give 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
• 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
• 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.

Give information to QROPS managers

Where a scheme manager has made a transfer to a QROPS, the scheme administrator needs to inform the scheme manager of the QROPS within 31 days of the transfer:

• whether a 25% tax charge applies to the transfer
• how much tax has been paid
• if the charge did not 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.