Record keeping (trustees of registered pension schemes)

As the trustee of a registered pension scheme you must keep accurate records so you can complete form SA970 Tax Return for the trustees of registered pension schemes at the end of the tax year. This means keeping information about the pension scheme's income and any trading activities. You don't need to send accounts or any other documents or records with the return, but you do need to keep them in case HM Revenue & Customs (HMRC) asks to see them.

On this page:

Records you must keep

You must keep records so that you can fill in a tax return fully and accurately.

The records you'll need to keep will depend on each pension scheme's individual circumstances - but the financial records might include details of all income, from sources such as:

  • interest on loans and deposits
  • bank and building society interest
  • interest on UK government securities
  • interest from authorised unit trusts
  • overseas investments
  • trading activities
  • Deeds of Covenant

For the tax return, you don't need records that relate to UK dividends.

If the pension scheme has foreign income, you'll need to keep a note of what the exchange rate was at the time the pension scheme became entitled to the income. You use that rate when you complete your return.

The more detailed records you keep, the easier it will be to answer any questions that HMRC has about the tax return. For example you may need to keep:

  • bank and building society statements, pass books, cheque stubs and paying-in slips
  • records of purchases and expenses if there's any trading activity

If records aren't kept to back up the information on a tax return, penalties may be payable. Up to £3,000 can be charged for each instance when the supporting records haven't been kept.


How long must you keep your records?

You must keep your records for a minimum period, as described below, in case HMRC decides to make a check into your return. The same dates apply whether you choose to file on paper or file online.

If the pension scheme has business income

If the pension scheme has business income, for example it owns property to let, you must keep the business records for five more years after the normal filing deadline of 31 January.

For example, for a 2013-14 tax return filed on or before 31 January 2015, you must keep the records until 31 January 2020.

If the pension scheme doesn't have business income

Providing you send in the tax return on or before 31 January, you should keep your records for one more year from the normal filing deadline of 31 January.

For example, for a 2013-14 tax return filed on or before 31 January 2015, you must keep your records until 31 January 2016.

If you send the return back after 31 January

If you send the return back after 31 January, either because it was issued late or because you sent it back late, you should keep your records until the latest of the following dates:

  • 15 months after the date you sent the return in
  • 5 years after the normal 31 January filing deadline if they are business records

If HMRC starts a check

You may need to keep your records for longer than the dates above if a check has already been started - in this case you'll need to keep your records until HMRC writes and tells you they've finished the check.

Read more about checks into tax returns

Tax return deadlines and penalties - find out more


If your records are lost or destroyed

Sometimes records are lost or destroyed - for example in a fire or flood - and are difficult to replace. If this has happened let HMRC know and do your best to recreate the missing records. Once you've managed to get the replacement information together use this to complete the tax return.

You must tell HMRC whether any figures are:

  • estimated - you want HMRC to accept these as final figures
  • provisional - you are using these until you can confirm the figures (you must tell HMRC when you will be supplying actual figures)

Use the 'Additional Information' section to say how you've arrived at these figures and the reason why you can't use actual figures. If you make adjustments at a later date and you've underpaid tax you may have to pay interest and penalties.


Getting help and advice

Administering a pension scheme can be complex. If you're already a trustee - or you're thinking about becoming one - you may want to get advice from a solicitor. You may also find it helpful to talk to a tax adviser or accountant too - see the 'More useful links' section below.

If you have any problems completing your tax return, please contact Pension Schemes Services.

Find contact details for the Pension Schemes Service


More useful links

Search for a solicitor on the Law Society website (Opens new window)

Find a tax adviser at the Chartered Institute of Taxation website (Opens new window)

Find a chartered accountant on The Institute of Chartered Accountants in England & Wales (ICAEW) website (Opens new window)