The pension age rises to 57 on 6 April 2028

On 6 August 2026 HMRC opened a technical consultation on the draft Normal Minimum Pension Age Transitional Provisions Regulations. It closes at 11:59pm on 28 September 2026.

9 min read · Altro Partners, by Equity & General

280 days

in which an entitlement can be established under the old rules for a client born 1 July 1972, and 36 days for a client born 1 March 1973

Illustration using two made-up clients

Reacting to

Normal Minimum Pension Age Transitional Provisions Regulations — technical consultation, HM Revenue & Customs, opened 6 August 2026

The draft regulations settle the position of a specific group of people who will be unable to take their pension for up to two years, and that group can be identified today from a field an accountancy practice already holds for every client and every director on a payroll: their date of birth.

The change and the two dates

From 6 April 2028 the normal minimum pension age, the earliest age at which benefits can normally be taken from a pension scheme, rises from 55 to 57 (Finance Act 2022). What has been unclear for five years is the position of people caught mid-way, and that is what August's draft regulations address.

Two dates of birth divide every client list into three groups:

Born before 6 April 1971

They are 57 or older on 6 April 2028. Nothing changes for them.

Born on or after 6 April 1973

They are under 55 on 6 April 2028, so the old age was never available to them. They wait until 57.

Born between 6 April 1971 and 5 April 1973

They turn 55 before the change but are 55 or 56 on the day it happens. A window opens on their 55th birthday, closes on 5 April 2028 and does not reopen until their 57th birthday.

Dates per Finance Act 2022 and HMRC’s draft Normal Minimum Pension Age Transitional Provisions Regulations, published for consultation on 6 August 2026. Uniformed service schemes, ill-health retirement and members with a protected pension age are outside this picture.

What the draft regulations protect

Some people in the middle group will have become entitled to benefits before 6 April 2028 without the money having been paid. Without a rule, those payments could fail to be authorised payments after the age changed.

The draft regulations treat a member who is 55 or 56 on 5 April 2028 as having reached 57 immediately before certain payments are made. That covers pension income payments, stand-alone lump sums, pension commencement lump sums, pension commencement excess lump sums and trivial commutation lump sums, and preserves access to a later trivial commutation payment following an earlier qualifying one. Payments from an entitlement established under the old rules can still be made after the change.

The regulations do not create a general right to keep drawing. A new crystallisation on or after 6 April 2028, whether a fresh designation into drawdown, a new annuity purchase or an uncrystallised funds pension lump sum, requires the member to have reached 57. A client who has partly crystallised will find the remaining uncrystallised funds unavailable until their 57th birthday.

Rachel Vahey, Head of Public Policy at AJ Bell, said when HMRC published the draft that it had "taken five long years" for savers to be told how the change would affect them, described the rules as taking a harsh line with no wiggle room, and warned that they could create an incentive to access a pension in full instead of in stages.

An illustration with two dates of birth

Illustration using two made-up clients. The arithmetic uses dates only. Both are owner-managers with a personal pension of around £400,000, and both intend to take some of it when they step back from the business.

A couple in their fifties going through paperwork at the kitchen table

Born 1 July 1972

Reaches 55 on 1 July 2027. From that date to 5 April 2028 there are 280 days in which an entitlement can be established under the old rules. After that the next opportunity is 1 July 2029, a wait of 15 months.

Born 1 March 1973

Reaches 55 on 1 March 2028. The window is 36 days. After that the next opportunity is 1 March 2030, a wait of 24 months.

Eight months of difference in date of birth gives one client 280 days and the other 36. On a £400,000 pot the tax-free element under current rules is up to £100,000 (gov.uk, Tax when you get a pension).

Taking benefits early also has costs. Taking taxable income from a money purchase pension brings in the money purchase annual allowance, which cuts the amount that can be contributed with tax relief from £60,000 to £10,000 a year (gov.uk, Tax on your private pension contributions). From 6 April 2027 most unused pension funds count in the estate for inheritance tax (Finance Act 2026), covered in when the pension joins the estate. Whether to act is a decision for the Equity & General financial planner with the client.

Why the accountant sees it

Two facts are needed at the same time. The first is a date of birth. It is in the payroll record submitted on every Full Payment Submission, on the personal tax file, and in month and year on the Companies House director record. A practice can list everyone born between 6 April 1971 and 5 April 1973 in an afternoon.

The second is what the client intends to do. A pension provider knows the birthday, and not that the client has agreed in principle to buy out a co-shareholder in 2029, or that the freehold the company trades from is coming up for sale, or that they have set a date to stop. Those come up in the year-end meeting, and the FCA's targeted support regime cannot see them either, as set out in targeted support is live and works from provider data.

The FCA's Financial Lives 2024 survey found that 8.6% of UK adults had taken regulated financial advice in the previous twelve months, and 13% of the self-employed. On those figures most of the clients now aged 53 to 55 have had no advice in the past year. See the advice gap.

Two things to do this week

Run the date-of-birth filter. Query payroll and client records for anyone born between 6 April 1971 and 5 April 1973. The list is fixed, because it depends only on dates of birth. Mark the director-shareholders and the clients with a known business event in 2028 or 2029.
Add one line to the year-end agenda. A question: is there anything you expect to need pension money for before 2030? A yes is a reason for a conversation with the financial planner. If the answer is no, no further action is needed. Other situations of the same kind are in six situations in the accounts that call for a financial planner.

Where the line sits

Identifying a cohort by date of birth is a database query. Telling a client that a dated statutory change affects them, and that the Equity & General financial planner is the person to work it through, is an introduction. A view on whether to take the money, how much, or into what is regulated advice.

The introduction is made through the portal with a written note of what the client agreed could be passed on, and the regulated work is done by Equity & General. The steps are in how the partnership works for one client.

What is not yet settled

The regulations are in draft. The consultation closes at 11:59pm on 28 September 2026 and the final instrument may differ from the 6 August version. The change of age on 6 April 2028 is settled. The transitional mechanics are what the consultation decides.

Protected pension ages have a separate test. A member may keep the right to take benefits earlier if their scheme rules on 11 February 2021 gave them an unqualified right to do so, needing no employer or trustee consent (Finance Act 2022). That is a question for the scheme administrator, and it survives a transfer only in limited circumstances: an individual transfer ring-fences the protected benefits in the receiving scheme, while a block transfer of more than one member can carry it across.

Uniformed service schemes for the armed forces, police and firefighters are outside the increase, as is retirement on ill-health grounds.

Common questions

Which clients are affected by the pension age rise on 6 April 2028?

Three groups, split by two dates. Anyone born before 6 April 1971 is 57 or older on 6 April 2028 and is unaffected. Anyone born on or after 6 April 1973 is under 55 on that date and waits until 57. The group born between 6 April 1971 and 5 April 1973 reaches 55 before the change but is 55 or 56 on the day it happens; for them a window opens at 55, closes on 5 April 2028 and does not reopen until 57. Uniformed service schemes and ill-health retirement sit outside this, and some members hold a protected pension age under their scheme rules. The dates of birth are in a practice's payroll records.

If a client turns 55 before April 2028, can they still take pension benefits afterwards?

Only for an entitlement that arose before 6 April 2028. HMRC's draft Normal Minimum Pension Age Transitional Provisions Regulations, published for consultation on 6 August 2026, treat a member who is 55 or 56 on 5 April 2028 as having reached 57 immediately before certain payments are made. That protects pension income, pension commencement lump sums, stand-alone lump sums and trivial commutation payments where the entitlement was established under the old rules. It does not create a general right to keep drawing. Any new crystallisation on or after 6 April 2028, whether a fresh designation to drawdown, a new annuity or an uncrystallised funds pension lump sum, requires the member to have reached 57.

Should an accountant suggest a client accesses their pension before April 2028?

No. Whether and when to take pension benefits is regulated advice. Taking taxable income from a money purchase pension brings in the money purchase annual allowance, which cuts what can be contributed with tax relief from £60,000 to £10,000 a year (gov.uk, Tax on your private pension contributions), and from 6 April 2027 most unused pension funds count in the estate for inheritance tax (Finance Act 2026). The accountant names the date and introduces the client to the Equity & General financial planner through the portal.

What is a protected pension age?

A protected pension age lets a member take benefits before the normal minimum pension age because their scheme already allowed it. For the increase to 57, the test is whether the scheme rules on 11 February 2021 gave the member an unqualified right, needing no employer or trustee consent, to take benefits before 57 (Finance Act 2022). It is a scheme-by-scheme question, and it survives a transfer only in limited circumstances: an individual transfer ring-fences the protected benefits in the receiving scheme, while a block transfer of more than one member to the same scheme can carry it across. The scheme administrator holds the answer.

Why would an accountant see this before the pension provider does?

The provider knows the date of birth and nothing about the client's plans. What turns 6 April 2028 into a decision is a share buy-back, a property purchase, a retirement date, a co-shareholder to buy out, or a business that needs capital in 2029, and those come up in the year-end meeting. The practice holds both the date of birth in the payroll and the client's stated intention for the next three years.

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