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Pension Death Valuations: The 28-Day Clock Starts When Executors Ask

ended 17. July 2026

From 6 April 2027, the person liable for the inheritance tax on someone's unused pension is the executor, not the pension scheme. New regulations, SI 2026/818, made on 13 July 2026 and laid before the House of Commons on 15 July 2026, insert a new regulation 10C into the Registered Pension Schemes (Provision of Information) Regulations 2006, setting out how that executor is meant to get the figures they need. Regulation 10C says a scheme administrator "must provide to the personal representatives of a deceased member" the scheme's details, whether the pot was investment-regulated, and the value of the pension at the date of death.

The catch sits in the next paragraph. That information is due "within the period of 28 days beginning with the day on which a request for it is received". The clock does not start when someone dies. It starts when the executor asks. Where the first figure is only a provisional estimate, the actual value follows within 14 days of it being worked out. Meanwhile the inheritance tax itself falls due at the end of the sixth month after death.

So the duty is real, but the timing is reactive. Nothing in regulation 10C makes the duty itself conditional on a request. Only the 28-day deadline is, and until the executor asks, there is no deadline for the scheme to miss. Someone who does not know the right exists can burn months of a six-month deadline waiting for a letter that no deadline compels anyone to send. The person caught is not a wealthy estate with a solicitor on retainer. It is the son or daughter, named in a will, working through a parent's paperwork at the kitchen table.

  1. A rule forcing schemes to answer within 28 days looks like a protection for executors. Is a right to information whose clock only starts if you already know to ask for it a protection at all, or a duty dressed up as one?
  2. From April 2027 the executor is liable for the tax but cannot calculate it without the scheme's cooperation. Who is hit hardest by making the timing of that cooperation reactive rather than automatic, and is it fair?
  3. What should families and advisers put in place before 6 April 2027 so the request goes out in week one rather than month four? Do you have a client whose plans this would change? If so, please give as much colour and detail as possible.


 

4 responses from the Newspage community

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Editor
Harvey Dhillon
Founder & CEO at Zmartly
Picture a daughter, three months after her mother's funeral, still waiting for the pension scheme to write to her. From 6 April 2027 an unused pension counts as part of the estate, and the executor is the one liable for the inheritance tax on it. New regulations made on 13 July 2026 do give her a right to the numbers: the scheme must hand over the pension's value at the date of death within 28 days. But read the wording. Those 28 days begin on the day "a request for it is received". The scheme is not late. It is waiting. A deadline that only starts when you ask is no use to someone who does not know to ask. The inheritance tax is due at the end of the sixth month after death, so every week she does not know is a week of that clock gone. So if you are named as an executor, write to every scheme in the first fortnight, before probate, before valuations, before anything else. The first move is yours. Nobody is coming to make it for you.

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Editor
Samuel Mather-Holgate
Managing Director & IFA at Mather and Murray Financial
From April 2027, executors are being told that you owe the tax, now go and find the numbers yourself. That is absurd. The 28-day rule looks like a safeguard, but it is really a trapdoor. The clock does not start when someone dies, or when HMRC needs paying, but only when a grieving executor knows the right question to ask the right pension scheme. That is not consumer protection; it is bureaucracy with a stopwatch hidden in a drawer. The best-advised estates will cope. The people punished will be ordinary sons and daughters sorting through a parent’s paperwork, unaware that silence from a pension provider does not mean nothing is due. Families and advisers need a week-one checklist: find every scheme, request death values immediately, chase provisional figures, and assume nothing arrives unless demanded.
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Antonia Medlicott
Founder & MD at Investing Insiders
The new regulations will easily catch executors out who have been given much more responsibility. Many will assume pension providers automatically share the necessary valuations with the estate, but the changes increase the risk of delays, and families may bear the consequences of missing a deadline they had little practical chance of meeting.

This raises a broader fairness issue, as someone acting for a parent or spouse may not even know how many pensions existed, let alone which schemes they need to contact immediately after a death and the strict tax deadlines they need to adhere to.

Families need to prepare by making sure loved ones know where pension arrangements are held. Keep an up-to-date record of providers and policy numbers alongside wills and other estate documents. Financial advisers should also update estate planning checklists to make it easier. Spending an hour organising records today could save months of unnecessary delays and stress for family members later.
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Editor
Nouran Moustafa
Practice Principal & IFA at Roxton Wealth
The government has transferred the liability before transferring the visibility. A 28-day deadline that begins only when a grieving executor knows the right question to ask is not meaningful protection; it is a trapdoor hidden in the paperwork.

The people hit hardest will not be wealthy estates with lawyers on standby. It will be ordinary sons and daughters juggling grief, work and a parent’s scattered financial records while a six-month tax clock keeps running.

Before April 2027, every family should create a pension inventory listing each provider, policy number and contact route, keep nominations updated, and leave executors a clear “week one” instruction to notify every scheme and request the date-of-death valuation in writing. Advisers should build this into annual reviews now. The reform targets pension wealth, but weak administration risks punishing the least prepared rather than the wealthiest.