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Does a UFPLS trigger the MPAA? (and what else does)
A UFPLS triggers it; tax-free cash on its own doesn’t. The line between flexible access that sets the MPAA off and benefits that leave it untouched.
4 min read · Last reviewed
Yes. Taking an uncrystallised funds pension lump sum (UFPLS) is a trigger event for the money purchase annual allowance (MPAA). From the date of the UFPLS, the most the member can pay into defined-contribution pensions with tax relief drops to £10,000a year — and carry-forward can't lift that ceiling.
What triggers it — and what doesn't
The MPAA is aimed at flexible access: drawing taxable income flexibly from a DC pot, of which a UFPLS is one form (25% tax-free, 75% taxable, in a single lump). The events that set it off and those that leave it alone are specific:
- UFPLS
- Triggers
- Income from a flexi-access drawdown fund
- Triggers
- A flexible (post-2015) annuity
- Triggers
- Tax-free cash (PCLS) on its own
- Does NOT trigger
- Capped drawdown income within the old limits
- Does NOT trigger
- Small-pots commutation (≤£10,000)
- Does NOT trigger
- A scheme pension or lifetime annuity
- Does NOT trigger
So the line is: take onlythe tax-free cash and move the rest into drawdown without drawing income, and the MPAA isn't triggered. Take a UFPLS, or start drawing income from the drawdown fund, and it is. Defined-benefit accrual is never a DC trigger.
What the trigger costs
Once triggered, DC input above £10,000 in a tax year attracts an annual allowance charge — and, unlike the standard allowance, no carry-forward can be set against the MPAA. Say the member triggers the MPAA, then pays £15,000 into a DC pension:
- DC pension input
- £15,000
- Money purchase annual allowance
- £10,000
- Carry-forward available against the MPAA
- £0
- Amount carried to the AA charge
- £5,000
The classic slip is assuming tax-free cash triggers it (it doesn't), or that carry-forward can soak up the excess over £10,000 (it can't — see MPAA and carry forward). Test DC input against the cap, with the default-versus-alternative working shown, on the MPAA calculator, or see the whole position alongside the taper and carry-forward on the pension annual allowance calculator. Signed in, the working prints to a compliance-annex PDF for the file.
PTM056500 (money purchase annual allowance ; trigger events) · £10,000 from 2023/24 per Finance (No. 2) Act 2023
Common questions
- Does taking a UFPLS trigger the MPAA?
- Yes. An uncrystallised funds pension lump sum is a flexible-access trigger event (PTM056500). From the date of the UFPLS, defined-contribution input above £10,000 a year attracts an annual allowance charge, and carry-forward can’t be set against that cap.
- Does taking tax-free cash trigger the MPAA?
- No. Taking only the pension commencement lump sum (tax-free cash) and moving the rest into drawdown — without drawing taxable income — does not trigger the MPAA. It’s drawing the taxable income flexibly (or a UFPLS) that sets it off.
- How much is the MPAA?
- £10,000 a year for 2023/24 onwards (it was £4,000 from 2017/18 to 2022/23). It caps defined-contribution saving that gets tax relief once you’ve flexibly accessed a DC pot.
- Does the MPAA stop defined-benefit accrual too?
- No. The MPAA only limits defined-contribution input. Defined-benefit accrual is tested separately against an “alternative annual allowance” (the normal allowance minus the MPAA), so DB benefits can keep building.
Sources & grounding
- Trigger basis: HMRC PTM056500 (money purchase annual allowance) — the listed trigger events (UFPLS, flexi-access drawdown income, flexible annuity, etc.) and the events that do NOT trigger it (PCLS/tax-free cash alone, capped drawdown within limits, small-pots commutation, scheme pension, lifetime annuity).
- Figure: £10,000 MPAA from 2023/24 (Finance (No.2) Act 2023; previously £4,000), held in the engine config (mpaaAmount), applied by app/calc-engine/pension/mpaa.ts.
- Worked charge (£15,000 DC input − £10,000 MPAA = £5,000; carry-forward against the MPAA £0): re-used from the published money-purchase-annual-allowance explainer (articles.tsx).
For planning and illustration purposes only. Verify all inputs against source documents. This explainer does not constitute financial or tax advice.