Mandatory scheme pays
If the conditions are met for mandatory scheme pays, the scheme must pay the charge and reduce benefits accordingly.
To invoke this form of mandatory scheme pays, the individual must notify the scheme they wish to use ‘scheme pays’ by 31 July in the year following the tax year to which the annual allowance charge relates. It's not possible for the individual to tell the scheme before the end of the tax year in which the charge relates to. The scheme may impose an earlier deadline to give them time to process the request and pay the charge before the payment deadline.
For example, if an individual has an annual allowance tax charge for the 2025/26 tax year, and meets the conditions for mandatory scheme pays, they must ensure their request is with the scheme before 31 July 2027. The scheme must then pay the charge before 14 February 2028.
This deadline will be brought forward in a year they want to make use of scheme pays if the individual:
- intends to take all their benefits from the pension scheme, or
- will reach age 75 and one or more of the following events happen in relation to their pension scheme at age 75:
- defined benefit rights not yet in payment in the pension scheme will remain undrawn
- uncrystallised funds in an other money purchase arrangement or cash balance arrangement in the pension scheme will remain as uncrystallised funds
- drawdown pension funds in the pension scheme that started after 5 April 2006 will still be in place.
This will allow the scheme to make any annual allowance tax charge payments before the benefits come into payment.
Voluntary scheme pays
If the individual doesn’t meet the conditions, the scheme could (but is not obliged to) apply scheme pays on a voluntary basis.
If the scheme agrees to pay an amount of an individual’s annual allowance charge liability on a voluntary basis, the scheme is not jointly and severally liable for the tax charge and the liability for the annual allowance charge will remain with the individual. The deadline for voluntary scheme pays is earlier than mandatory scheme pays, it is 31 January in the year following the tax year to which the annual allowance charge relates.
So, in the example above the deadline for paying the charge on a voluntary basis is brought forward to 31 January 2027.
For voluntary scheme pays, it is up to the scheme to apply whatever deadline for notification it thinks will give it enough time to process the request and pay the charge before the payment deadline.
HMRC Pensions Tax Manual - PTM056420 Annual allowance: tax charge: scheme pays: deadlines