Overseas aspects of pension schemes

Types of overseas pension schemes

There are four types of overseas schemes:

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Overseas Pension Schemes
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Qualifying Non-UK Pension Schemes (QNUPS)—essentially an Overseas Pension Scheme which satisfies prescribed conditions if the relevant member state does not happen to have a system in place for the approval of pension schemes for tax purposes
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Recognised Overseas Pension Schemes (ROPS)—essentially a QNUPS which satisfies additional criteria
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Qualifying Recognised Overseas Pension Schemes (QROPS)—essentially a ROPS which has notified HMRC of that fact and has provided evidence of that fact

For more information on the features of those overseas schemes, see Practice Notes:

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Types of overseas pension schemes
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Qualifying Recognised Overseas Pension Scheme (QROPS)

Transfers to and from overseas pension schemes

As workers become more internationally mobile, pension schemes find themselves dealing with more frequent requests to transfer members' pension benefits to and from overseas schemes.

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Latest Pensions News

TPR encourages DC trustees to have their say on VfM consultation reforms before March deadline

The Pensions Regulator (TPR) has published a blog encouraging trustees of defined contribution (DC) pension schemes to respond to the joint TPR and the Financial Conduct Authority (FCA) consultation paper CP26/1 which outlines how the new value-for-money (VfM) framework could operate by setting out proposals designed to move DC workplace pensions away from narrow cost-based assessments towards a more holistic and comparable evaluation of the value delivered to DC pension savers. TPR is asking trustees to respond by the consultation deadline as trustee input is essential to shaping a VfM framework that they will be responsible for applying in practice. Trustees are expected to drive improvements in value, challenge advisers and providers, and use the framework to identify and address poor outcomes. Feedback is particularly timely because the framework will be implemented for trust-based schemes through forthcoming government legislation, so responses now will help inform both the final design of the framework and TPR’s future regulatory approach. The consultation closes on 8 March 2026.

Pensions weekly highlights—22 January 2026

This week’s edition of Pensions weekly highlights includes a review of key news stories, as well as dates for your diary and trackers.

National Insurance Contributions (Employer Pensions Contributions) Bill: HoC backs pension salary sacrifice reform despite opposition

The House of Commons (HoC) completed the Committee of the Whole House and Third Reading Stages of the National Insurance Contributions (Employer Pensions Contributions) Bill on 21 January 2026, assisting the progress of the introduction from 6 April 2029 of a £2,000 cap above which salary-sacrificed employer pension contributions will have a primary and secondary Class 1 National Insurance contributions (NICs) charge applied. At Committee stage, opposition parties sought to narrow or delay the measure and to require further scrutiny, but the government, represented throughout by Torsten Bell, the Parliamentary Secretary to the Treasury and Minister for Pensions, resisted all proposed changes and the Bill emerged unamended. On the same day at Third Reading, Torsten Bell said reform was inevitable because of the rising cost of pension salary sacrifice and defended the Bill as a pragmatic compromise that retained £2,000 of NIC-free saving with a long lead-in period. Despite opposition MPs opposing the Bill on the grounds of complexity, distributional impact, and pension adequacy, the Commons passed the Bill unamended by 316 votes to 194 and it now proceeds to the House of Lords.

Pension Schemes Bill: Employer surplus-payment provisions pass Grand Committee scrutiny unchanged

At the third day of Grand Committee on the Pension Schemes Bill on 19 January 2026, the House of Lords undertook an extensive examination of Clauses 9 (Power to modify scheme to allow for payment of surplus to employer) and 10 (Restrictions on exercise of power to pay surplus), with debate focused on a series of amendments that tested how far the new surplus release regime should be constrained in primary legislation. In particular, peers tabled amendments seeking to change the terminology from ‘surplus’ to ‘assets’, to require surplus to be shared with members, to mandate benefit enhancements including inflation protection, to strengthen member notification or consultation (including trade union involvement) in the surplus release process, to constrain the Secretary of State’s regulation-making powers, to embed actuarial and endgame requirements in statute, and to alter insolvency priorities where employers had previously extracted surplus. The government response, delivered principally by Baroness Sherlock, consistently resisted the amendments to prescriptive statutory rules governing the use of surplus or the processes surrounding its release, and instead defended the Bill’s reliance on trustee discretion, fiduciary duties, actuarial certification, and regulatory oversight by the Pensions Regulator. All amendments were either withdrawn or not moved following government opposition, and Clauses 9 and 10 were agreed without amendment.