Insights · Tax and planning

The Pre-Budget Question: What to Do When Clients Want to Act Before 28 October

9 min read · Altro Partners, by Equity & General

Reacting to: Budget speculation risks pushing clients into costly mistakes, AJ Bell warns (Money Marketing, 2 September 2026) →

The Budget is on 28 October 2026. The Chancellor's letter to the Treasury Select Committee confirming the date was published on GOV.UK on 31 July 2026, which means that as of today there are fifty-six days of speculation to get through and nothing whatsoever has been announced. In that window, a particular kind of phone call starts arriving in accountancy practices: the client who has read something, does not want to be caught out, and wants to do something about it now.

AJ Bell put a warning out this morning, reported by Money Marketing, that advisers face a surge in clients wanting to make damaging decisions ahead of the Budget — withdrawing pension tax-free cash early, crystallising capital gains, or making gifts they cannot afford. The warning is aimed at financial advisers. The practical problem is that most of these clients do not have one. They have an accountant, and the accountant is who they ring.

This is not a hypothetical pattern

Sarah Coles, head of personal finance at AJ Bell, pointed to what happened before the 2024 Budget, when speculation about restrictions to pension tax-free cash contributed to savers withdrawing an additional £10bn, according to Financial Conduct Authority data cited in the Money Marketing report. That is the measurable footprint of a rumour. No rule changed; the money left anyway, and for a large share of those savers it is not going back.

Coles framed the risk plainly: “As the weeks wear on, we can expect more of this, and there's an increasing danger that people feel they need to take steps ‘just in case’ that they could sorely regret later.”

There is a scale point underneath it. The Pensions Commission, whose interim report was published in May 2026, has estimated that 14.6 million people are not saving enough for retirement, and AJ Bell notes that figure increases by a further two million if people withdraw and spend their tax-free cash. Coles also cited 2024 Department for Work and Pensions research showing that a one-off purchase was the most common use of tax-free cash among people taking only part of their entitlement. Money taken out under pressure does not tend to sit in a deposit account waiting to be reconsidered.

The asymmetry that makes this different from ordinary tax planning

Most tax decisions an accountant handles are symmetrical. Get the timing slightly wrong on a dividend and next year corrects it. The four decisions AJ Bell lists are not like that. Each one is cheap to delay and expensive to reverse, and the cost of being wrong is not distributed evenly between the two options.

Tax-free cash. Once a pension commencement lump sum is paid it is out of the pension for good, and the amount counts against the standard lump sum allowance of £268,275 set out in GOV.UK's guidance on individual lump sum allowances. Rebuilding it means fresh contributions inside the annual allowance, which GOV.UK's pension schemes rates page, updated 6 April 2026, sets at £60,000 for 2026 to 2027. If the Budget leaves tax-free cash alone, the client who waited has lost nothing at all. The client who acted has moved money out of a tax-sheltered wrapper permanently.

Capital gains. GOV.UK gives Capital Gains Tax at 18% within the basic rate band and 24% above it from 6 April 2026, with an annual exempt amount of £3,000 for 2026 to 2027. Selling now to beat a possible rise pays a certain 24% today to avoid an uncertain higher rate later. Worth saying to any client who repeats the standard line about realising gains gradually: at £3,000 and a 24% rate, the annual exemption is worth £720 a year. The gradual-realisation argument is a fraction of what it used to be, which cuts in both directions and is worth knowing before the conversation rather than during it.

Gifts. GOV.UK's guidance on Inheritance Tax and gifts confirms the seven-year rule, taper relief running from 32% on gifts made three to four years before death down to 8% at six to seven years, and a £3,000 annual exemption. What none of that addresses is the risk AJ Bell actually identifies, which is affordability. A gift made in October out of fear is gone whether or not the fear was justified.

Stopping. The fourth one is the quietest. Coles warned against pausing regular contributions or investments while waiting to see what happens: “The key to regular investments is the regularity, so think long and hard before pausing your plans based on a fear of something that may never happen.” A client who suspends a pension contribution for a quarter has made a decision too, and nobody will flag it because nothing visible happened.

Waiting costs nothing if the rumour is wrong. Acting costs a great deal. That is the whole shape of the problem, and it is arithmetic rather than opinion.

What it actually costs: a worked example

Take an owner-manager aged 57 with a £400,000 defined contribution pot, still running the business, no immediate need for cash. He reads that tax-free cash might be capped, and asks his accountant whether he should take his £100,000 now.

Suppose he does, and nothing changes in the Budget. The £100,000 leaves a wrapper where investment returns are sheltered and lands somewhere they are not. Say it sits in a deposit account or general investment account returning 4%, so £4,000 of interest a year. His income already makes him a higher-rate taxpayer, so his Personal Savings Allowance is £500 rather than £1,000, and £3,500 of that interest is taxed at 40% — £1,400 a year, every year, on money that produced no tax charge at all the month before.

He has also used £100,000 of his £268,275 lump sum allowance to achieve nothing, and put £100,000 into his estate today rather than leaving it in a pension. There is one point in his favour worth stating accurately: taking the tax-free lump sum on its own does not trigger the money purchase annual allowance — that comes from taking taxable income flexibly — so his £60,000 annual allowance survives. If he had drawn taxable income alongside it, GOV.UK's pension schemes rates page puts the money purchase annual allowance at £10,000, and his ability to put business profits back into a pension would have fallen by £50,000 a year.

Now suppose he waits, and tax-free cash is restricted on 28 October. He is worse off than if he had acted. That is real, and pretending otherwise would be dishonest. But the comparison a client needs is not between two outcomes, it is between a certain, permanent, immediate cost and a possible one — and it is a comparison nobody makes in their head while reading a newspaper. It takes about ten minutes to set out on paper. That is accountancy work, and it is the single most useful thing a practice can do in the next eight weeks.

Why this lands on the accountant

The lang cat's State of Advice Report 2025 put the proportion of UK adults who had paid for regulated advice in the previous two years at 9%, and the average age of an IFA client at 59. The client in the example above — mid-fifties, wealth concentrated in a business and a pension, no adviser — is precisely the person the advice market has not reached, and precisely the person for whom a pre-Budget mistake is largest. Our overview of the advice gap sets out how that population is shaped.

So the question arrives at a practice that can answer half of it authoritatively and must not answer the other half at all. The half an accountant owns is factual and substantial: what the current rules are, on what date, from which published source; what the decision costs in tax if taken; what it costs if taken and the rumour proves wrong; and what it costs to wait, which is usually nothing. None of that requires FCA authorisation.

The half that cannot be answered without authorisation is the one the client actually asked: should I do it. Telling a client to take the lump sum, sell the holding or make the gift is a personal recommendation on a regulated activity. The distinction is about permissions and liability rather than knowledge, and it matters more than usual in a pre-Budget window because the pressure to give a straight answer is at its highest exactly when the answer is least knowable.

Two things worth doing this week

Write the holding answer down before the calls come. Three or four sentences, used consistently by everyone in the practice: the Budget is on 28 October, nothing has been announced, here is what the rule is today with its source, here is what acting early would cost you in tax whether or not the rumour is right, and the decision about whether to act needs someone authorised to look at your whole position. Having that written down turns an awkward call into a two-minute one, and stops different people in the same firm giving different-sounding answers over eight weeks.

Run one list, not a full review. Pull the clients aged 55 and over with a defined contribution pension, and the clients holding significant unrealised gains outside an ISA. Those two groups contain almost everyone who might act badly before 28 October. In most practices the combined list is short enough to read in a sitting, and it is far more useful to have it before the calls start than to assemble it afterwards from the ones who rang. Our note on the CGT signal covers what shows up in the accounts on the gains side.

What is still uncertain, and when it will be known

Everything about the contents. The date is fixed at 28 October 2026 and the Office for Budget Responsibility publishes its updated economic and fiscal outlook the same day. Beyond that, no measure on pensions, Capital Gains Tax or Inheritance Tax has been announced, and anything written about them before that date is speculation regardless of how confidently it is expressed. AJ Bell has called on the government to introduce a tax lock guaranteeing the future of pension tax relief and tax-free cash; that is a lobbying position, not a policy.

Two further things are open even after the date. Where a measure takes effect from is as important as whether it happens, and immediate-effect measures are what genuinely punish waiting while dated-from-April measures do not. And the interaction with the inheritance tax treatment of unused pension funds from April 2027 pulls in the opposite direction to almost everything above, since a client who empties a pension early is solving one problem by creating another — we covered that change in when the pension joins the estate, and the tax position of retired clients more broadly in the higher-rate retirement.

What is not uncertain is where the questions will land. For most owner-managers there is one professional they discuss money with, and between now and 28 October that professional will be asked to sanction a decision that cannot be taken back. The useful response is not a view on the Budget. It is the arithmetic of acting early set against the arithmetic of waiting, and a route to someone authorised to take it from there.

Common questions

Why does a pre-Budget question land on the accountant before it lands on an adviser?

Because the accountant is the professional most owner-managers already have. The lang cat's State of Advice Report 2025 put the proportion of UK adults who had paid for regulated advice in the previous two years at 9%, which means around nine in ten do not have a financial planner to ring. They do have an accountant, they speak to that accountant about money, and they treat a Budget rumour as a tax question rather than an investment one. So the call arrives in a practice that is qualified to explain the tax consequence of a decision and not authorised to recommend the decision itself. Recognising which half of the question has arrived is the whole skill here.

Is taking tax-free cash from a pension reversible if the Budget changes nothing?

No. Once a pension commencement lump sum is paid, the money is out of the pension permanently and the amount is set against the standard lump sum allowance of £268,275, which GOV.UK's guidance on individual lump sum allowances confirms. There is no mechanism to put it back beyond making fresh contributions inside the annual allowance, which GOV.UK's pension schemes rates page, updated 6 April 2026, sets at £60,000 for 2026 to 2027. A client who withdraws £100,000 in October and finds in November that nothing changed cannot restore the position. That asymmetry is the reason the timing question matters more than the tax rumour does.

Does crystallising capital gains early actually save tax if rates rise?

Only if rates rise, and the certain cost is paid immediately. GOV.UK gives Capital Gains Tax at 18% within the basic rate band and 24% above it from 6 April 2026, with an annual exempt amount of £3,000 for 2026 to 2027. Selling now to beat a possible rise means paying 24% today on gains that might otherwise have been deferred for years, and losing the compounding on the tax paid. It is worth noting that the annual exempt amount at £3,000 is worth £720 a year at 24%, so the old argument about realising gains gradually is far weaker than it was. Neither point tells a client what to do; both belong in front of them before they decide.

What is the risk in a client making large gifts ahead of the Budget?

Affordability, not tax. GOV.UK's guidance on Inheritance Tax and gifts confirms that no tax is due on a gift if the giver survives seven years, that taper relief runs from 32% for gifts made three to four years before death down to 8% at six to seven years, and that £3,000 of gifts each tax year sit outside the estate under the annual exemption. None of that changes the fact that a gift is gone. AJ Bell's warning, reported by Money Marketing on 2 September 2026, is specifically that people give away more than they can afford because they fear a future rule change and then find themselves short later in retirement.

What does a joined-up response to a pre-Budget question look like in practice?

It separates the two halves of the question and answers them in order. The accountant answers the factual half — what the current rules are, what the decision costs in tax if it is taken, what it costs if it is taken and the rumour proves wrong — using dated published sources rather than press speculation. The regulated half, which is whether the client should take the lump sum, sell the holding or make the gift, goes to an authorised adviser who can see the client's wider position. The accountant is not being asked to hand the relationship over. They are being asked to make sure the client has both halves before 28 October, rather than one half in a hurry.

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