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Death benefits and IHT · Inheritance tax (from 2027)

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.

3 min read · Last reviewed

— In short

Finance Act 2026 received Royal Assent on 18 March 2026 and applies to deaths on or after 6 April 2027. Information-sharing regulations SI 2026/818 were laid on 15 July 2026. HMRC’s 27 August technical note explains that process, while further regulations, guidance and support tools remain due before commencement.

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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. The information-sharing regulations have also been laid; further consequential rules and HMRC guidance remain to come.

The timeline, status checked 8 September 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
15 July 2026
SI 2026/818 information-sharing regulations laid
27 August 2026
HMRC technical note 2 published
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’s August technical note distinguishes the July regulations from the draft identity guidance and notice templates in its annexes. Further regulations on split schemes and excepted estates are still planned.

Further income-tax guidance is scheduled for autumn; final guidance and support materials are planned for spring 2027. The pension-apportionment tool is still forthcoming: this process update does not establish final HMRC pension-attribution arithmetic.

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) · SI 2026/818 (laid 15 July 2026) · HMRC technical note 2 (27 August 2026)

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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 further consequential regulations and guidance still being completed.
Were the information-sharing regulations still draft on 20 July 2026?
No. SI 2026/818 had already been laid on 15 July 2026. The earlier version of this guide relied on the consultation page and missed that instrument; HMRC’s August technical note confirms the date.
When will HMRC publish final pension-IHT guidance?
HMRC’s August timetable schedules further technical material in autumn and final guidance and supporting materials for spring 2027. Some notice templates and identity guidance remain draft. Check the latest publication before relying on a process or deadline.

Sources

Based on Finance Act 2026, SI 2026/818 and HMRC’s May and August 2026 technical notes; status checked 8 September 2026.

  1. Technical note 2: Further information on Inheritance Tax and Pensions gov.uk
  2. Finance Act 2026 legislation.gov.uk
  3. Technical note: Inheritance Tax on pensions gov.uk
  4. Inheritance tax on pensions — information sharing regulations gov.uk
  5. The Registered Pension Schemes (Provision of Information) (Miscellaneous Amendments) Regulations 2026 legislation.gov.uk

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