The Pensions Management Institute (PMI) welcomes the opportunity to respond to HMRC’s consultation on the draft clauses of the Finance Bill 2025–26. As the professional body supporting trustees and pensions professionals across the UK, the PMI is committed to ensuring that legislative reform is proportionate, practical, and aligned with the statutory duties and member-facing responsibilities embedded within the pensions sector.

The PMI has serious concerns regarding the proposed registration requirements for tax advisers. As currently drafted, the legislation broadens the scope of the proposals far beyond that envisaged by the Minister and risks unintended consequences for pensions practitioners who are legally required to provide tax-related information to scheme members and routinely interact with HMRC. These interactions - such as the provision of Pension Savings Statements to scheme members and submission of scheme returns to HMRC - are mandated by pensions legislation and do not constitute discretionary tax advice. It is therefore essential that HMRC clarify whether such transactions are intended to fall within scope of the registration provisions.

The PMI stands ready to support further dialogue and provide detailed observations to ensure that the legislation is coherent, proportionate, and fit for purpose.

To read the full response, please click download below.

Download