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Updating pre‑A‑Day UK pension scheme rules: trustee checklist on Finance Act 2004 reforms and transitional measures (archived)

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ARCHIVED: This archived Checklist outlines the matters trustees would have needed to assess when revising their scheme rules to reflect the legislative changes that took effect on 6 April 2006 (A‑day). It is provided for background purposes only. For more detail, see Practice Note: Updating your rules to reflect A‑day changes [Archived].

A-day—an overview

On 6 April 2006, the Finance Act 2004 (FA 2004) commenced, bringing in a new framework for taxing UK pension schemes. The principal reforms were:

  • the former tax approval regime was replaced with registration by HM Revenue & Customs (HMRC)
  • in place of strict caps and limits on benefits, a more flexible approach was adopted, applying tax charges to ‘unauthorised payments’ and where members’ benefits exceed the annual and lifetime allowance

Transitional provisions

To prevent a sudden rise in pension scheme liabilities following the removal of previous caps and limits, transitional measures were introduced under the Registered Pension Schemes (Modification of the Rules of Existing Schemes) Regulations 2006, SI 2006/364 (the ‘Transitional Modification Regs’)...

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Web page updated on 20/05/2026

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