On 6 August 2026 HMRC opened a technical consultation on draft secondary legislation with one of the least inviting titles of the year: the Normal Minimum Pension Age Transitional Provisions Regulations. It closes at 11:59pm on 28 September 2026. On the face of it this is scheme-administrator plumbing, of interest to pension providers and nobody else.
It is not only that. What the draft regulations settle is the position of a specific, finite group of people who are about to lose access to their own 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 that split your client list
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. That has been legislated since Finance Act 2022 and is not in doubt. What has been unclear for five years is what happens to people caught mid-stride, 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 in practice. They wait until 57, and always were going to.
- Born between 6 April 1971 and 5 April 1973. This is the group that matters. They turn 55 before the change but are only 55 or 56 on the day it happens. A window opens on their 55th birthday, slams shut on 5 April 2028, and does not reopen until their 57th.
What the draft regulations protect, and what they do not
HMRC’s concern is that some people in the middle group will already have become entitled to benefits before 6 April 2028 without the money having been paid. Without a rule, those payments could fail to qualify as authorised payments after the age changed, purely because of the calendar.
The draft regulations fix that by treating a member who is 55 or 56 on 5 April 2028 as having reached age 57 immediately before certain payments are made. The consultation document extends that treatment to 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. A decision taken under the old rules is honoured under the new ones.
What the regulations do not do is create any general right to keep drawing. A new crystallisation on or after 6 April 2028 — a fresh designation into drawdown, a new annuity purchase, an uncrystallised funds pension lump sum — requires the member to have actually reached 57. A client who has partially crystallised will find the remaining uncrystallised funds sealed until their 57th birthday.
Rachel Vahey, Head of Public Policy at AJ Bell, commented on the detail when HMRC published it that it had “taken five long years” for savers to be told how the change would affect them, describing the rules as taking a harsh line with no wiggle room, and warning that they could create a perverse incentive to access a pension fully rather than in stages.
The regulation protects a decision already taken. It does not protect the client who was going to get round to it.
Putting real numbers on it
The following is illustrative arithmetic rather than a real client, and it is built on dates rather than on investment returns.
Two owner-managers, both with a personal pension of roughly £400,000, both intending to release some of it around the time they step back from the business.
- 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. Miss it, and 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 wide. Miss it, and the next opportunity is 1 March 2030 — a wait of 24 months.
Four months of difference in a date of birth produces a nine-fold difference in the time available to make a decision. Neither client has done anything wrong, and neither is likely to know the dates exist. On a £400,000 pot, the tax-free element under current rules is up to £100,000, which for many owner-managers is the single largest liquid sum in their financial life.
And the arithmetic runs in both directions, which is exactly why this is not a nudge to act. Taking taxable income from a money purchase pension triggers the money purchase annual allowance, permanently cutting the amount that can be contributed with tax relief from £60,000 to £10,000 a year. From 6 April 2027, unused pension funds fall into the estate for inheritance tax, which reshapes the question again — a change covered in when the pension joins the estate. Rushing at the window can cost more than missing it. That is precisely why the decision belongs to a regulated adviser and not to a spreadsheet.
Why this lands on an accountant’s desk first
Spotting this needs two facts held at the same time, and almost no one holds both.
The first is a date of birth. It is in the payroll record, submitted to HMRC on every Full Payment Submission; it is on the personal tax file; the month and year sit on the Companies House director record. A practice can produce the list of everyone born between 6 April 1971 and 5 April 1973 in an afternoon.
The second is what the client actually intends to do. A pension provider knows the birthday and nothing else. It does not know that the client has agreed in principle to buy out a co-shareholder in 2029, or that the freehold the company trades from comes up for sale, or that they have quietly set a date to stop. Those things surface in a year-end meeting, which is why the FCA’s new targeted support regime, for all its reach, cannot see them — the point made in targeted support is live.
The other reason is scale. The lang cat’s State of Advice Report 2025 found that just 9% of UK adults had paid for financial advice in the preceding two years, while 91% of those who did found it valuable, and put the average age of an IFA client at 59. A cohort currently aged 53 to 55 is, on those numbers, mostly unadvised — and the deadline that applies to them arrives before the age at which the advice market typically meets them. The size of that mismatch is set out on the advice gap.
Two things worth doing this week
Run the date-of-birth filter. Query payroll and client records for anyone born between 6 April 1971 and 5 April 1973. For most practices this returns a few dozen names, not hundreds, and it is a fixed list that will never grow. Flag the director-shareholders and the clients with a known business event in 2028 or 2029; that is the short list where the timing genuinely bites.
Add one line to the year-end agenda. Not a recommendation, a question: is there anything you expect to need pension money for before 2030? A yes is a signal. A no closes it. Either way the question is asked in time to be useful, rather than in 2029 when the only honest answer is that the window has gone. Other signals of the same kind, already visible in work a practice does anyway, are collected in the six signals already sitting in your client file.
Where the line sits
None of the above asks an accountant to advise on pensions. Identifying a cohort by date of birth is a database query. Telling a client that a dated statutory change affects them, and that a regulated planner is the person to work it through, is an introduction. What would cross the line is a view on whether to take the money, how much, or into what.
The practical protection is the same as it always is: no product named, no course of action recommended, a written note of what the client agreed could be passed on, and the regulated work done by the authorised firm that carries responsibility for it. What that handover involves, step by step, is set out in the anatomy of an introduction.
What is not yet settled
Three things are genuinely open, and it is worth separating them from the parts that are fixed.
The regulations are still in draft. The consultation closes at 11:59pm on 28 September 2026, and the final instrument may differ in detail from the version published on 6 August. The underlying change of age on 6 April 2028 is not in question; the precise mechanics of the transitional treatment are.
Protected pension ages are a separate question with a separate test. A member may hold a 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. That is a matter for the scheme administrator, and it can be lost or preserved on transfer depending on whether the transfer is individual, in which case the protected benefits are ring-fenced in the receiving scheme, or a block transfer of more than one member.
Finally, scope. Uniformed service schemes — armed forces, police and firefighters — are outside the increase, as is retirement on ill-health grounds. A client in one of those categories is in a different position and should not be worked through the timeline above.
What is not uncertain is the date, the cohort, or who is holding the information. The change is legislated, the two birth dates that define the affected group are arithmetic, and the field that identifies them is already in the payroll.
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 in practice. Anyone born on or after 6 April 1973 is under 55 on that date and simply waits until 57. The group in between, 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 that identify the middle group are already in a practice’s payroll records.
If a client turns 55 before April 2028, can they still take pension benefits afterwards?
Only in respect of 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 to take pension benefits, and when, is regulated financial advice, and the accountant’s role stops at noticing that a dated change applies to a particular client. Acting early carries real costs that cut the other way: taking taxable income from a money purchase pension triggers the money purchase annual allowance, permanently cutting what can be contributed with tax relief from 60,000 pounds to 10,000 pounds a year, and from 6 April 2027 unused pension funds fall into the estate for inheritance tax, which changes the calculation again. Naming the date and introducing the client to an authorised firm is an introduction. Recommending a course of action is not.
What is a protected pension age, and could a client already have one?
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 contained a provision giving the member an unqualified right, one needing no employer or trustee consent, to take benefits before 57. It is a scheme-by-scheme question rather than a client-by-client one, 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?
Because the provider knows the date of birth and none of the things that make it matter. What turns 6 April 2028 from a diary entry into a decision is the client’s own plan: a share buy-back, a property purchase, a retirement date, a co-shareholder to buy out, a business that needs capital in 2029. That sits in the year-end conversation, not in a provider’s records. An accountancy practice is the only professional relationship that holds both halves, a date of birth in the payroll and a stated intention for the next three years. Bringing the two together takes a filter and a question, neither of which is a regulated activity.