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The road to April 2027: what is law, what is draft, and the deadlines that matter

The tax itself is law. Parts of the process behind it are not final yet. This dated timeline keeps those two things clearly apart.

Based on Finance Act 2026, HMRC’s May 2026 technical note and the GOV.UK information-sharing regulations consultation page, status checked 20 July 2026.

6 min read · Last reviewed

— In short

The tax is law: Finance Act 2026 got Royal Assent on 18 March 2026 and applies to deaths on or after 6 April 2027. The process behind it is not all finished — at 20 July 2026 the information-sharing consultation had closed but no outcome or final regulations had been published. HMRC says the final guidance, manual updates, templates and support tools will follow in time for April 2027.

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Is this actually happening, or could it still change? The core answer is that the tax is already law. Finance Act 2026 got Royal Assent on 18 March 2026 and applies to deaths on or after 6 April 2027. What is not finished is some of the machinery around it — how information is shared and how claims are made — which still depends on secondary rules and later HMRC guidance. This page keeps the two apart.

The timeline, status checked 20 July 2026

Pension IHT: enacted, draft and pending
18 March 2026
Finance Act 2026 receives Royal Assent — enacted
11 May / 29 May 2026
HMRC technical note published / updated
18 May–11 June 2026
Draft information regulations consultation — closed
20 July 2026
Feedback analysis shown; no final outcome on GOV.UK
For April 2027
HMRC guidance, manuals, templates and tools — pending
6 April 2027
New treatment starts for deaths on or after this date

What the law already settles

Quite a lot. The Act pulls most unused pension funds and death benefits into inheritance tax (calling that value notional pension property), leaves a few specified benefits out and keeps the usual recipient exemptions. It puts the personal representatives in charge, gives them the power to hold benefits back and to have a scheme pay HMRC directly, and sets the income-tax adjustment for where a pension has borne inheritance tax.

One thing worth being clear on: it is the date of death that decides which rules apply, not when the pension is paid out. Die before 6 April 2027 and the current rules apply even if the money comes through later; die on or after that date and the new rules apply.

What was not finished at the review date

HMRC ran a consultation on draft rules for the information that has to pass between personal representatives, schemes, beneficiaries and HMRC. It ran from 18 May to 11 June 2026. On 20 July the official page still just said HMRC was analysing the feedback, with no outcome published — so the deadlines, the notice process and the templates were still draft, not final.

HMRC says the guidance, manual updates, evidence requirements, hold-back and payment templates and support tools will all be published in time for April 2027. The post-75 income-tax claim mechanics wait on that same material. So this page needs a fresh look once the regulations are made, and again when the final guidance lands.

Which guide answers which question

The enacted overview is in pensions, death benefits and inheritance tax and the scope explainer is pensions and inheritance tax from April 2027. The Pension IHT calculator states its April 2027 basis and keeps guidance-pending attribution separately labelled. For planning and illustration only; not financial, tax or legal advice.

Finance Act 2026 · HMRC “Inheritance Tax on pensions” technical note (11 May 2026 ; updated 29 May) · GOV.UK information-sharing regulations consultation (18 May–11 June 2026) · Royal London (9 June 2026)

Common questions

Are the April 2027 pension inheritance-tax rules law?
Yes. Finance Act 2026 received Royal Assent on 18 March 2026 and brings most unused pension funds and death benefits into inheritance tax for deaths on or after 6 April 2027. That enacted scope is distinct from the operating regulations and guidance still being completed.
Which pension IHT rules were still draft in July 2026?
The secondary information-sharing regulations were still at consultation stage when checked on 20 July 2026. The consultation had closed and HMRC was analysing feedback; no outcome or final regulations were published on that page at the review date.
When will HMRC publish final pension-IHT guidance?
HMRC’s May 2026 technical note says guidance, tax-manual updates, templates and supporting tools will be published for April 2027. The note describes an indicative timetable, so current GOV.UK material needs checking again as commencement approaches.
Sources & grounding

For planning and illustration purposes only. Verify all inputs against source documents. This explainer does not constitute financial or tax advice.