It was confirmed with the publication of the draft Finance Bill 2025-26 that measures first announced in the Autumn Budget 2024 to bring most unused pension funds and death benefits into the scope of Inheritance Tax (IHT) will start from 6 April 2027. This will significantly extend the IHT net, capturing pensions that were previously excluded. Individuals with sizeable pensions will need to consider these changes with some care, and review their estate planning accordingly.

This measure will affect individuals inheriting estates within the scope of IHT, including beneficiaries of any unused pension funds or death benefits included in those estates. Personal representatives will be liable for reporting and paying any IHT due on unused pension funds and death benefits.

Death-in-service benefits payable from a registered pension scheme and dependants’ scheme pensions from a defined benefit arrangement, or from a collective money purchase arrangement are excluded from these changes and will not be within the scope of IHT.

There were some changes to the original proposals following a technical consultation that closed in January 2025. As a result, personal representatives, rather than pension scheme administrators, will now be primarily liable for reporting and paying IHT on any unused pension funds and death benefits.

This means that pension scheme administrators and personal representatives will need to work together in administering IHT on pensions. There are concerns that this process could lead to multiple issues, including payment delays, greater complexity and GDPR privacy matters.