RPSM11103690 - Technical Pages: Lifetime allowance: The process for testing: After member's death: Step 4

Step 4: actions the individual’s personal representatives must take

[Reg10, The Registered Pension Schemes (Provision of Information) Regulations 2006 SI 2006/567]

If a chargeable amount arises the personal representatives must make a report or further report to HMRC of the amount and lifetime allowance charge due by the following deadlines


  • the later of the following two dates
  • 13 months after the individual’s death, or
  • 30 days after the personal representatives became aware that there was a chargeable amount to report (that is, when they have received information about any relevant lump sum death benefit paid from a schemeadministrator that indicates that the deceased individual’s lifetimeallowance has been exceeded),
  • where the above time limit has expired when the requirement to report arises, or is paid after the personal representatives have made a report under the first bullet above, within 30 months of the individual’s death, or
  • where the personal representatives learn of any reportable payments later than 30 months from the individual’s death, within 3 months of that discovery.

Both of the authorised lump sum death benefits that constitute a relevant lump sum death benefit must be paid within 2 years of the scheme administrator learning of the member’s death or if they could reasonably be expected to have known sooner, 2 years from that earlier time (in order to be classified as such payments). Any such payments made after the 2 year deadline will be an unauthorised member payment (unless one of the other authorised lump sum death benefits, not within the relevant lump sum death benefit definition), and will be taxed as such. The above reporting requirements and lifetime allowance charge provisions do not apply to such payments ( RPSM11102100 explains why).

There is no prescribed form required, but the information that must be provided to HMRC is as follows


  • the name of the registered pension scheme from which the relevant lump sum death benefit (or benefits) has been paid, along with the name and address of the scheme administrator,
  • the name of the deceased member in respect of whom the relevant lump sum death benefit was paid,
  • the amount(s) and date(s) of payment of the lump sum death benefit payment(s) made under the registered pension scheme, and
  • the level of chargeable amount that arose due to those payments

Where a chargeable amount has arisen following the payment of more than one relevant lump sum death benefit from more than one registered pension scheme only one (amalgamated) report should be made. A report per scheme is not necessary.

If the personal representatives are satisfied there is no chargeable amount they do not have to make a report to HMRC.

Where a report is due, personal representatives who fail to report or who make reports outside the time limits may be liable to penalties.


Glossary ( RPSM20000000)