07 April 2026
HM Revenue and Customs (HMRC) has now confirmed that pension administrators are exempt from the new registration requirement.
Although Part 7 of the Finance (No. 2) Bill introduces a rule requiring payroll only service providers to register for an Agent Services Account (ASA) from 18 November 2026, these exemptions mean that pension administrators are not required to register under this change.
Early draft legislation would have required pension administrators and practitioners to register. In response to the feedback from the pensions industry, exemptions in Schedule 19 (exceptions) have been extended. These have been announced in a newsletter from HMRC to include:
- pension scheme administrators.
- pensions practitioners.
- scheme managers of qualifying overseas pension schemes.
- qualifying recognised overseas pension schemes.
- responsible persons for employer-financed retirement benefit schemes.
Additionally, if there is no interaction with HMRC about the clients’ tax affairs, for instance providing information about Annual Allowance charges or holding pre-retirement information sessions, then there is no requirement to register.
Please be mindful that interactions which are not caught by this exemption, and which involve providing tax advice to clients and interacting with HMRC, would require registration with HMRC.
Payroll only service providers are individuals or organisations that assist clients with their tax affairs by providing tax advice, acting as a tax agent, or helping with documentation likely to be relied upon by HMRC to determine someone’s tax position. It also applies to providers who work for, or who interacts with HMRC on behalf of, the tax advisor.
This includes providers who do, or attempt to do, the following:
- Contact HMRC by telephone, post or email.
- Send a message to HMRC through a website or internet portal.
- File a return, claim, notice or another document with HMRC (whether electronically or otherwise).
- Communicate with HMRC in any other way.
To register for an ASA, businesses must be supervised by an Anti-Money Laundering supervisor.
For anyone wishing to sign up early, registration opens on 17 May 2026, with the final date to register being 18 February 2027.
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