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Pensions in the estate from 6 April 2027: the client conversations an advice firm has to get through in the next eighteen months, and a plan for the workload
From 6 April 2027 unused pensions count in the estate and personal representatives pay the tax. Which clients to see first and how a small firm schedules it.

From 6 April 2027 most unused pension funds and death benefits will be included in the value of the estate for inheritance tax. The government's response to its technical consultation, published on 21 July 2025, settled the question the industry had argued about: personal representatives, not pension scheme administrators, will be responsible for reporting and paying the tax. HMRC's technical note sets out how. The providers have written the technical explainers. This guide is about the firm's calendar.
What changed, in four lines
Unused pension funds and most death benefits join the estate for IHT from 6 April 2027. Personal representatives report and pay, with the pension's share of the tax calculated across the estate. PRs or prospective PRs can instruct the scheme to withhold 50% of the benefit for up to 15 months after the end of the month of death, and PRs or beneficiaries can instruct the scheme to pay the tax to HMRC directly. Death-in-service benefits from registered schemes were taken out of scope in the July 2025 response.
Why it is a workload problem
A Scottish Widows survey of advisers in April 2026 found 57% saying their clients were uncertain about the change and 55% recommending lifetime gifting in response. Every client with a pension and an estate near or above the nil-rate bands has a decision to make before April 2027, and some of those decisions (gifting, drawing more, changing beneficiary nominations, life cover, spending) take months to put into effect. For a firm with 300 clients of whom 120 are affected, that is 120 conversations, each needing a valuation, an estate picture and a written recommendation, in the eighteen months from the response to the start date, of which about six have passed.
Who first
Order the list by the size of the pension against the estate and by the client's age and health, because the clients for whom the change costs most and the time is shortest come first. Then clients whose expression of wish or nomination has not been reviewed in five years, because the beneficiary question changes under the new rules. Then clients already in drawdown whose withdrawal rate was set to preserve the pension for the next generation. Then everyone else at their next annual review, which is where the ongoing service tracker puts them.
What each meeting needs
A current valuation of every pension and the estate; the nominations on file; the client's own view of what the pension is for; and a recommendation, written as a suitability report where a transaction follows, that explains the options and their disadvantages. The file check applies to each; a recommendation to gift or to draw more has disadvantages that the report must state, and the Consumer Duty's understanding outcome applies to a subject most clients find hard.
The calendar
Eighteen months, 120 clients, one meeting each plus preparation and a report: roughly seven a month on top of the normal review cycle, which for a two-adviser firm is a real load. The preparation is where the time goes, and most of it is administrative: pulling valuations, sending letters of authority, chasing them, assembling the estate picture, drafting the report on the firm's template. The advice is the adviser's and takes an hour; the pack takes a day.
In the firm
An AI Review Coordinator set up by Overlyft builds the affected-client list from the back office, orders it on the firm's criteria, books the meetings into the review calendar and prepares each pack; the Document Chaser gets the valuations and nominations in; the Report Drafter drafts the report for the adviser to decide, amend and sign. Nothing here is a recommendation to any client, and the tax position of any individual is the adviser's to assess with the client's other professionals. General information from the published government response and HMRC note; not tax or financial advice.
Short answers from this page
Who pays inheritance tax on unused pension funds from April 2027?
The personal representatives of the estate, not the pension scheme administrator. From 6 April 2027 most unused pension funds and death benefits count in the estate. Personal representatives can instruct the scheme to withhold 50% of the benefit for up to 15 months, or to pay the tax to HMRC directly. Death-in-service benefits from registered schemes are out of scope.
Source: HM Treasury and HMRC response, 21 July 2025; HMRC technical note
Every short answer for financial advisers and mortgage brokers
Where this comes from: HM Treasury and HMRC, Inheritance Tax on unused pension funds and death benefits: summary of responses and government response, 21 July 2025; HMRC technical note on inheritance tax on pensions (GOV.UK); Royal London and M&G adviser technical notes read 2026-10-01; Scottish Widows adviser survey, April 2026 (57% say clients are uncertain, 55% recommend lifetime gifting). Not tax or financial advice; the adviser owns every recommendation.
AEO Lookup editorial team
We write practical guides for people who run small UK firms, and we check every fact against its source on the date shown. Read how we review, or tell us if something has changed.



