NMPA TRANSITIONAL PROVISIONS: WHAT NEWSLETTER 180 TELLS US

HMRC published Pension Schemes Newsletter 180 in April 2026, providing the first detailed — if still provisional — guidance on the transitional regulations that will accompany the increase in the Normal Minimum Pension Age (NMPA) from 55 to 57 on 6 April 2028. The guidance is provisional and subject to change once the draft regulations are published for technical consultation, but it gives an important early steer on how the rules are expected to operate.

What is the NMPA?

The NMPA is the earliest age at which an individual can access benefits from a UK registered pension scheme without triggering an unauthorised payments tax charge. The NMPA is currently age 55, rising to age 57 on 6 April 2028.

The increase does not apply to members of the uniformed services pension schemes (armed forces, police and firefighters), who remain exempt.

Who is affected?

The change creates three distinct groups:

• Born before 6 April 1971 — will have reached 57 by 6 April 2028 and are unaffected.
• Born on or after 6 April 1973 — will be under 55 on 6 April 2028 and can only access benefits from age 57.
• Born between 6 April 1971 and 5 April 1973 — these individuals will be aged 55 or 56 on 6 April 2028. It is this cohort that the transitional regulations primarily address.

The core transitional principle

The central aim of the transitional regulations is straightforward: members who have already become entitled to pension benefits before 6 April 2028 should be able to continue receiving those payments as authorised payments after that date, even if they are not yet aged 57.

The mechanism used is a deeming provision — for the purpose of post-6 April 2028 payments, the member is treated as having reached age 57 immediately before that payment, provided they had already crystallised or become entitled to that benefit before that date.

Pension payments — what the transitional rules cover

Newsletter 180 sets out how the transitional provisions apply to different benefit types:

Drawdown, annuities and scheme pensions already in payment or designated

Where a member aged 55 or 56 on 5 April 2028 has already:

• designated funds into flexi-access drawdown,
• applied funds towards the purchase of a lifetime annuity, or
• become entitled to a scheme pension,

those benefits can continue to be paid on or after 6 April 2028 as authorised payments.

Importantly, the protection also extends to a member who has become entitled to a benefit before 6 April 2028 but has not yet taken their first payment. For example, where a member designates funds into flexi-access drawdown in June 2026 aged 55, but does not take their first drawdown income until May 2028 when they are aged 56, the transitional regulations will treat that member as having reached NMPA for the purposes of those payments. The drawdown income will be an authorised payment.

The same principle applies where a member became entitled to a scheme pension or lifetime annuity before 6 April 2028 but the first payment falls after that date.

Pension Commencement Lump Sum (PCLS)

Where a member aged 55 or 56 on 5 April 2028 has already become entitled to a PCLS (so all of the conditions under  the scheme rules have been met such that they have a right not merely an intention to receive the lump sum) — but payment has not yet been made, that lump sum can still be paid on or after 6 April 2028 as an authorised payment.

Uncrystallised Funds Pension Lump Sums (UFPLS)

The position for UFPLS is more restrictive. AnUFPLS is only an authorised payment where it is paid after the member has reached the NMPA at the time of payment. Any UFPLS paid on or after 6 April 2028 will therefore only be authorised if the member has reached age 57. There is no deeming provision for UFPLS. Any UFPLS already paid before 6 April 2028, which was authorised at that time, remains authorised.

The planning issue for partially-crystallised clients

This does create a potential gap for clients who will be aged 55 or 56 on 6 April 2028 and have only partially crystallised their pension. Uncrystallised funds remaining in their pension on that date cannot be accessed until they reach age 57, which may be up to two years away. For clients who anticipate needing liquidity during that gap, it may be worth discussing whether crystallising further funds before 6 April 2028 is appropriate. This is particularly relevant where the client wishes to take an UFPLS or designate additional funds into drawdown after that date.

New crystallisations after 5 April 2028

The transitional rules only protect arrangements already in place before 6 April 2028. Any new crystallisation event — designating further uncrystallised funds into drawdown, purchasing a new annuity, or taking an UFPLS — on or after 6 April 2028 will require the member to have reached age 57, unless a protected pension age or ill-health exception applies.

Transfers of pensions already in payment

Newsletter 180 also addresses the position where a member who has already started their pension — having reached the pre-2028 NMPA — transfers their crystallised rights on or after 6 April 2027 whilst not yet aged 57. Under the existing provisions of SI 2006/499 (the Registered Pension Schemes (Transfer of Sums and Assets) Regulations 2006), the replacement pension in the receiving scheme is treated as if it were the original pension, and payments can continue as authorised payments.

Ill-health exceptions

The ill-health and serious ill-health rules are unchanged by the NMPA increase.

To access benefits on ill-health grounds, the member must provide the scheme administrator with evidence from a registered medical practitioner confirming that they are, and will continue to be, medically incapable (physically or mentally) of carrying on their current occupation as a result of injury, sickness, disease or disability. The member must also have ceased to carry on that occupation.

Where a member’s life expectancy is less than one year, a serious ill-health lump sum may be available. This is generally tax-free up to the remaining lump sum and death benefit allowance, and requires medical evidence confirming the life expectancy.

Closing note

HMRC has confirmed it will provide further detail once the draft transitional regulations are ready for technical consultation. The guidance in Newsletter 180 should be treated as an early indication of the intended framework, not a definitive statement of the final rules. A further update will follow once the regulations are published.

All information is based on our understanding and interpretation of applicable law and regulation which is subject to change. Tax treatment depends on individual client circumstances and may change in the future.