Form IHT409: telling HMRC about pensions
What form IHT409 asks, box by box, how to get the figures from pension schemes, and what changes for deaths on or after 6 April 2027. Checked Oct 2026.
How pensions are treated for deaths before 6 April 2027
Death benefits. A lump sum or a pot that passes to someone as beneficiary's drawdown is a death benefit, and the IHT400 notes say it only counts as part of the estate if it was payable to the personal representatives, either by right or because nobody else qualified, or if the person could have signed a binding nomination right up to their death. Many schemes call their form a nomination but then say the trustees aren't bound by it, and HMRC treats that as a letter of wishes, so the scheme's wording matters more than the form's title. Where the trustees had discretion you still answer the questions, but the amount stays out of box 56. Death in service benefits usually work the same way.
Dependants' pensions. A reduced pension paid on to a surviving spouse or civil partner isn't part of the estate, which is why question 1 tells you to answer No when that's the only payment continuing.
Annuities with a guarantee. If the person bought an annuity with their pension and died within its guarantee period, the remaining payments are paid to the estate and their value is taxable, so you enter it at question 7 using the calculator figure.
Alterations in the two years before death. Changes made whilst someone is seriously ill can move value to other people, such as reducing drawdown income or putting off taking a pension, so HMRC asks about them. Its manual on lifetime transfers of death benefits explains that changes made more than two years before death normally show the person was in normal health at the time. You report the facts and HMRC reviews them after the grant, although you can put your own value on form IHT403.
Unregistered schemes. If a scheme isn't registered with HMRC, answer the IHT409 questions and also give details of the benefits in the IHT400 'Additional information' boxes.
What changes for deaths on or after 6 April 2027
Under the Finance Act 2026, most unused pension funds and death benefits form part of the estate for deaths on or after 6 April 2027, whether or not the trustees had discretion. Our guide to DC pensions and the April 2027 change covers the planning side, and HMRC's technical note on Inheritance Tax on pensions sets out the reporting rules below.
Some benefits stay outside the estate: death in service benefits, dependants' scheme pensions, dependants' or nominees' annuities bought together with the member's own lifetime annuity, and charity lump sum death benefits. The spouse and civil partner exemption still applies.
The personal representatives become responsible for reporting the pension and paying the tax on it, and a beneficiary becomes jointly liable with them once the pension money is paid out to that beneficiary. Scheme administrators aren't liable unless they ignore a valid notice, but they must give the personal representatives the value of the pension and the split between exempt and non-exempt beneficiaries within 28 days of a request, and each beneficiary's details and share within 28 days of a further request or 14 days of the beneficiaries being decided, whichever is later. Executors can ask for this before the grant is issued.
A withholding notice tells the scheme to hold back up to 50% of the taxable benefits until the tax is paid, for no longer than 15 months after the end of the month of death. A payment notice, under what HMRC calls the Pensions Direct Payment Scheme, tells the scheme to pay at least £1,000 of the tax straight to HMRC within 35 days. Pension money can't be paid by instalments or get Business or Agricultural Relief. Personal representatives also have to take reasonable steps to find every scheme, and HMRC says a certificate of discharge (form IHT30) will protect them from tax on a pension discovered later, provided they made those efforts.
As at 6 October 2026, HMRC hasn't published a revised IHT409 or said it will be replaced. Its second technical note says final guidance, notice templates and online tools will follow in spring 2027, and that the excepted estates rules will be amended so estates that include pensions can still qualify. For deaths before 6 April 2027 use the current IHT409, and for later deaths check GOV.UK for the version in force.
Paying the tax and finding everything else
Inheritance Tax must be paid by the end of the sixth month after the death, and the IHT400 can't be finished until every asset has a figure, so one missing account holds up everything. For the bank, utility and insurance accounts that make up the rest of it, Legacy Trail's account discovery service searches credit reference agency and Cifas data for accounts the family didn't know existed.
Frequently asked questions
For deaths before 6 April 2027, a pension death benefit paid at the trustees' discretion is normally outside the estate, although guaranteed payments and benefits payable to the estate are taxable. For deaths on or after that date, most unused pension funds and death benefits are included.
Yes. You still report the scheme and the death benefit, but you answer Yes at question 12 and leave the amount out of IHT400 box 56.
Yes. HMRC asks for a separate form for each pension and benefit, and a separate form for each death benefit payment.
HMRC hasn't published a new version or announced a replacement as at October 2026. It has said final guidance will follow in spring 2027.
This article is for general information only and does not constitute legal advice. Individual circumstances vary. If you are dealing with an estate, consider taking advice from a solicitor who specialises in probate. For other guidance specific to your circumstances, speak to a funeral director, Citizens Advice, or a regulated financial adviser.