HMRC has published a consultation on draft secondary legislation for changes to the information sharing regulations relating to imposing inheritance tax (IHT) on unused pension pots.

The draft regulations will update the pensions provision of information regulations following the passage of the Finance Act 2026, which brings unused pension and death benefits into a deceased individual’s estate for IHT purposes.

The changes will require pension providers and personal representatives to share information with one another, as well as pension beneficiaries and HMRC, in respect to relevant pension assets.

HMRC’s consultation confirms that the regulations will come into effect in relation to deaths on or after 6 April 2027.

The consultation outlined the information that would be required from each party when dealing with an estate’s pension assets relevant to IHT.

“This confirms the Treasury is pressing ahead with plans to bring unused pension pots and lump-sum death benefits within IHT calculations from 6 April 2027,” commented Utmost global wealth specialist, Marc Acheson.

“When we speak with wealthy individuals - long-term residents, entrepreneurs and business owners - the principal reason they point to for reviewing their UK residency is the expanding scope of IHT, particularly the application of IHT to family businesses that came into effect on 6 April 2026.

“IHT is now increasingly affecting more households, with around one in 20 estates currently paying IHT, and the Office for Budget Responsibility expects that figure to rise to roughly one in 11 by 2030-31 – almost double the proportion affected today."

HMRC published further details on how the new regime for pensions and IHT will operate earlier this month (March).

This set out the expected implementation timetable, including plans for further consultations and draft regulations later this year, while final guidance and supporting materials are not expected until spring 2027.

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