PTM166500 - Information and administration: information requirements when a member flexibly accesses their benefits: action a member must take if they had a flexible drawdown pension fund before 6 April 2015

Glossary PTM000001

Regulation 14ZD The Registered Pension Schemes (Provision of Information) Regulations 2006 - SI 2006/567

A member who had entered flexible drawdown under a registered pension scheme before 6 April 2015 may have to notify the schemes that they are a member of that they have flexibly accessed their pension savings.

The circumstances in which a member must notify that they have flexibly accessed their pension savings
When the notification must be made by
When the member doesn’t have to provide a flexible access notification

The circumstances in which a member must notify that they have flexibly accessed their pension savings

The member must tell the scheme administrator of any scheme under which they are an accruing member that they flexibly accessed their pension rights for the purposes of the annual allowance rules at the start of 6 April 2015.

An accruing member is a member who on or after 6 April 2016 is accruing benefits under a money purchase arrangement or a hybrid arrangement. Accruing benefits in this context means:

  • in the case of an other money purchase arrangement
    • a relievable contribution has been paid by or on behalf of the member
    • an employer has paid a contribution in respect of the member
    • a contribution made by an employer of the member but not in respect of the member, subsequently becomes held for the purposes of an other money purchase arrangement for the member.
  • in the case of a cash balance or hybrid arrangement there are presently arrangements for the accrual of benefits in respect of the member under the arrangement.

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When the notification must be made by

The member must make the flexible access notification within 91 days beginning with the later of:

  • 6 April 2015 - if the member was an accruing member of any scheme on that date,
  • if the member was not an accruing member of any scheme on 6 April 2015 - the first date that the member began accruing benefits under any scheme.

If the individual becomes an accruing member under a registered pension scheme, QROPS or former QROPS after the start of this 91-day period they must notify the new scheme administrator or scheme manager (as the case may be) within 91 days of starting to accrue benefits. However, this does not apply if the member joined the scheme as the result of a transfer made after 6 April 2015 that was a recognised transfer from a registered pension scheme.

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When the member doesn’t have to provide a flexible access notification

The member doesn’t have to give a flexible access notification to:

  • the scheme administrator of the registered pension scheme under which they took flexible drawdown before 6 April 2015.
  • a scheme administrator if they have already given them a flexible access notification under:
    • this provision
    • regulation 14ZB (member to notify after receiving a flexible access statement from a registered pension scheme administrator scheme notification) see PTM166400
    • regulation 14ZE (member to notify after voluntary conversion to flexi-access drawdown), see PTM166600.