The charge is law; the reporting chain is still being written

There are 198 days until 6 April 2027, when unused pension funds and pension death benefits enter the inheritance tax estate for deaths from that date. What the statute itself says — section 66 of the Finance Act 2026, the new section 150A of the Inheritance Tax Act 1984, the relief allowance that pays for the change — is settled law, read line by line elsewhere on this site. The operational question is the one where money actually moves, and it is not settled: an executor in Hong Kong with a UK scheme, or a London personal representative facing four of them, must run a chain of requests, notices and clocks that HMRC has only half-published.

The document that matters is HMRC's Technical Note 2 on Inheritance Tax and Pensions, published on 27 August 2026. It is not draft guidance — the note says so in its first section — but it is not the guidance either. What it does is turn a statutory charge into a sequence of exchanges between an estate and a pension scheme, and mark where the sequence stalls.

The document chain, and the gaps in it

Technical Note 1 arrived on 11 May 2026 with the core principles, valuation, and the first account of how a scheme verifies whoever is administering an estate. The information regulations — the Registered Pension Schemes (Provision of Information) (Miscellaneous Amendments) Regulations 2026, SI 2026/818 — were made on 13 July 2026 and laid before the House of Commons on 15 July, 65 days after Technical Note 1. Technical Note 2 followed 43 days later, on 27 August.

  • 18 March 2026 — Finance Act 2026 (2026 c. 11), ss.66–71. The charge, liability and the two notices, in statute.
  • 11 May 2026 — Technical Note 1. Core principles, valuation, evidence of a personal representative's identity, discharge certificates.
  • 13–15 July 2026 — SI 2026/818 made, then laid. The five information stages and their deadlines.
  • 27 August 2026 — Technical Note 2. The process in order, draft notice templates, draft identity guidance, clearance.
  • Autumn 2026 — Technical Note 3, promised. International issues, inheritance tax against income tax, intestacy, charities and trusts.
  • Autumn–winter 2026–27 — further statutory instruments. Split schemes; excepted estates.
  • Spring 2027 — final guidance and supporting tools. The templates in their final form.

From Technical Note 2 to commencement is 222 days; from today, 198. The regulations come into force on 6 April 2027 and the provisions that matter to an estate have effect only for deaths on or after that date, so a death in March 2027 follows the old rules even if the scheme pays out in May.

Five points of exchange, and the clock on each

SI 2026/818 inserts regulations 10C to 10M into the 2006 information regulations, creating five stages at which a personal representative and a scheme administrator must exchange information. Days are calendar days, the note says, and not every stage will happen — further information is only needed if an inheritance tax account has to be filed.

  • Basic information. The estate requests it; the scheme provides the scheme's name, the administrator's name and address, the member's reference and the value of the notional pension property within 28 days. If the value is a provisional estimate, the scheme must say why and give the actual figure within 14 days of establishing it.
  • Further information, where an account is required: each beneficiary's name and address, national insurance number where known, trust details, and the value and percentage each is entitled to — the later of 28 days from the request or 14 days after all beneficiaries are decided.
  • A withholding notice. The scheme must say within 14 days whether it accepts the notice as valid, then give the total withheld, and each beneficiary's share, within 28 days.
  • A payment notice under the pensions direct payment scheme, which lets an estate or a beneficiary direct the scheme to pay inheritance tax straight to HMRC. There is no deadline for submitting one, but the scheme has 35 days to pay, and the route cannot be used below £1,000.
  • Lump sum death benefits, where the estate needs the information to work out whether the deceased's lump sum and death benefit allowance has been exceeded.

The clock that does not start until the scheme says so

The most consequential sentence in the note is not about money. It says that once a scheme administrator has received the reasonable information and documentation it requires, any applicable response period begins to run. In practice the 28-day clock on a basic information request is not started by the request; it is started by the scheme being satisfied that the person asking has authority to act — and that decision is made without a grant of probate, because schemes must answer before the grant issues.

Technical Note 2 draws the working line. A named executor has title from the date of death, so an acting executor can give both notices and receive information before applying for a grant. Where no named executor can act — an intestacy, or an executor who will not serve — the individual is a prospective personal representative: entitled to request information and to give a withholding notice, but not to give a payment notice. HMRC is preparing guidance on the evidence schemes should accept; a draft sits at Annex A, and the final version is promised on GOV.UK in due course.

The asymmetry has an edge. Irwin Mitchell, the UK firm, said in a note dated 8 September 2026 that a prospective personal representative who cannot direct a payment may have to fund a liability from estate assets, or by borrowing, before a grant is obtained; its private client partner Naomi Neville called that "one of the most significant unresolved issues in the new regime". The restriction is in the note; the consequence is the firm's reading, and a fair one — a scheme that hears nothing from an estate is told to identify beneficiaries and distribute without further delay.

What can be withheld, and for how long

  • Withholding notice. Given by a personal representative or a prospective personal representative; caps payments to each beneficiary at up to 50% of their entitlement as at the date of death; runs up to 15 months after the end of the month of death, or until withdrawn or the tax is paid.
  • Payment notice. Given by a personal representative or a beneficiary, including a trustee; pays inheritance tax and interest directly to HMRC; the scheme must pay within 35 days, and the route cannot be used below £1,000.

Two details are easy to miss and expensive to get wrong. Withholding is fixed by the notional pension property at death, so growth in the pot afterwards sits outside the notice — the note's own example lets beneficiaries take their share of a £12,000 increase while the notice stands. And excluded benefits, plus anything payable to an exempt beneficiary such as a surviving spouse, civil partner or charity, cannot be withheld at all, which is why the draft form asks the estate to flag exempt beneficiaries early. A scheme administrator that fails to comply with a valid withholding notice becomes jointly liable for the tax attributable to those benefits.

Clearance, and the benefits nobody knew about

Personal representatives can be discharged from liability for inheritance tax on previously undiscovered pension benefits by obtaining clearance; beneficiaries then carry the liability, and the estate reports what it finds. The note sets the entry conditions: apply only after the account is filed, all tax believed paid and estate values believed final — in practice no earlier than 12 months after the death and 3 months after receiving the unique code for probate. Applications use form IHT30, and a Clearance Checker tool will be updated to account for pensions.

What a Hong Kong family should have ready

For a Hong Kong family with a UK scheme, or a family office with UK-resident members, the work is a short list that starts before the death rather than after it. Identify who will act and on what footing: a named executor evidences authority from the will, a death certificate, matching identity documents and a signed declaration accepting the role, while an intestacy or a declining executor pushes the estate onto the harder prospective route with no payment-notice power. Assemble that evidence before the first request goes out, because the deadline only starts once the scheme is satisfied. Diarise the request, decide in advance whether to give a withholding notice and on what reasoning, and keep the clearance timetable in view from the start.

The note does not yet answer the cross-border case. It states that all its examples assume the parties are long-term UK tax residents, and that future technical notes will cover situations where that is not so. The information regulations are drafted for registered pension schemes and for insurance companies paying an annuity bought with scheme money; how the chain runs where the executor is in Hong Kong and the scheme in London is, today, an open question. The paperwork side of a cross-border handover is where unprepared estates lose the most time, and the pension chain adds a new set of clocks to that list.

What to watch

Technical Note 3 is promised for autumn 2026 and expected to cover international issues, the interaction of inheritance tax with income tax, further intestacy guidance and the treatment of charities and trusts. After that come draft guidance shared with industry over the winter, statutory instruments on split schemes and excepted estates — until the excepted estates regulations are amended, whether a small pension-bearing estate needs an account at all stays unresolved — then final guidance and tools in spring 2027, ahead of commencement on 6 April 2027. For an estate with a UK pension, the useful preparation this autumn is not a calculation. It is a file of evidence, a named person who can use it, and a diary that starts when the scheme, not the family, says the clock is running.