Reporting requirements for non-registered pension schemes

By Tolley

The following Employment Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Reporting requirements for non-registered pension schemes
  • Introduction
  • Reporting requirements and EFRBS
  • Migrant member relief in relation to overseas pension schemes
  • Transfers to a registered pension scheme from an overseas pension scheme
  • Reporting requirements and QROPS
  • Non-reportable payments
  • Details to report
  • Other information that a QROPS may need to provide to HMRC
  • Changes to information supplied
  • Additional reporting requirements introduced in 2013 and 2105
  • Additional reporting requirements introduced in 2017
  • HMRC online reporting service


The non-registered pension schemes, in respect of which there are reporting requirements to HMRC, covered by this note are:

  • Employer Financed Retirement Benefit Schemes (EFRBS)
  • overseas pension schemes in respect of migrant member relief
  • transfers from overseas pension schemes to the UK
  • qualifying recognised overseas pension schemes (QROPS)
Reporting requirements and EFRBS

The relevant legislations are FA 2004, s 251(1)(a), (2)(e)–(f) and SI 2005/3453 (subscription sensitive).

There are two main areas where information must be provided to HMRC, as follows:

  • when the EFRBS started
  • annually, when benefits are provided from the EFRBS
When the scheme starts

By 31 January, following the end of the tax year in which a scheme comes into operation, the following must be sent to HMRC:

  • the name of the scheme
  • the name and address of the responsible person
  • the date the scheme came into operation

The named ‘responsible person’ is in charge of making this report and any subsequent annual reports. The ‘responsible person’ is defined in ITEPA 2003, s 399A.

A scheme ‘comes into operation’ on the first occasion when either of the following takes place:

  • an employer contributes to the scheme
  • benefits are provided from the scheme

The particulars required when a scheme starts should be sent to the trust office dealing with the trust through which the scheme

More on Non-registered pension schemes: