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Event Reports for the tax year 2024 to 2025

If you’re a scheme administrator of a public service pension scheme, you’ll need to report to HMRC if, as a result of the public service pensions remedy, you’ve issued new or revised versions of a:

• pension saving statement (PSS)
• money purchase saving statement (MPSS)
• Benefit crystallisation event (BCE) statement, where the member relied on protections to reduce their liability to the lifetime allowance charge that would otherwise have arisen

If you’ve issued a new or revised PSS, or MPSS, to a member as a result of the remedy, you must submit an event 22 or event 23 respectively, for each member for each tax year within the remedy tax years 2015 to 2016 to 2021 to 2022 for which a new or revised PSS or MPSS has been issued. This could be a:

• new PSS, where the member now meets the automatic requirements for issuing a PSS
• revised PSS, where the member had previously met the automatic requirements for a PSS, but has since had an increase or decrease in pension input amounts

If you issued a new or revised BCE statement and the member relied on protection, you will need to report this as an event 6.

If these events occurred as a result of the public service pensions remedy, you’ll need to submit these events on an Microsoft Excel spreadsheet instead of through the scheme’s Event Report on the Managing pension schemes service. The data you’ll need for each member is as follows:

Event 22 � PSS

You’ll need the:

• name of the member (title, first name, surname)
• National Insurance number of the member
• aggregate pension input amounts for the scheme
• tax year ending (that the PSS relates to)

Event 23 � MPSS

You’ll need the:

• name of the member (title, first name, surname)
• National Insurance number of the member
• aggregate pension input amounts for the scheme for money purchase arrangements under the scheme
• tax year ending (that the MPSS relates to)

Event 6 � BCE where the member relied on protections

You’ll need the:

• name of the member (title, first name, surname)
• National Insurance number of the member
• date of the BCE
• amount crystallised by the event
• type of protection held
• protection

While you may have issued a member affected by the public service pensions remedy a single new or revised PSS or MPSS covering multiple years, you must report individually for each tax year in which the annual allowance or money purchase limit was exceeded, rather than the tax year in which the PSS or MPSS was issued to the member.

The designated single point of contact (SPOC) for your scheme at HMRC will send you a copy of the template by email. If you have not received it, contact us at [email protected] and include ‘PSPR Event Reportingâ€� in the subject line. We’ll provide you with the spreadsheet template.

For reporting of all non-public service pensions remedy event 22 and event 23, you must continue to use the Event Report on the Managing pension schemes service.

The Public Service Pension Schemes (Rectification of Unlawful Discrimination) (Tax) Regulations 2025

Regulations related to the public service pensions remedy came into force in 2023:

• â€� SI 2023/113
• â€� SI 2023/912

have now been made and laid. These regulations make provision for the offsetting and reclaiming of unauthorised payments charges previously paid by scheme administrators on behalf of their members and other miscellaneous technical changes. These changes are set out in the following sections.

Recovery of unauthorised payments charges paid under the mandating procedure impacted by the remedy

In public service pensions remedy newsletter September 2024 we provided information about the offsetting and reclaiming processes for unauthorised payments charges affected by the remedy. The processes apply only when the scheme administrator paid the unauthorised payments charge to HMRC on behalf of their member.

Unauthorised payments charges or scheme sanction charges that have become overpaid by the scheme administrator due to the remedy can be offset against the unauthorised payments charge or scheme sanction charge due on additional (top-up) unauthorised payments arising from the remedy. However, if there is no top-up unauthorised payment, or the amount of the overpaid tax is more than the tax due on the top-up payment, tax may be reclaimed only if the original unauthorised payment (called a historic payment under the regulations) was made on or after 6 April 2019.

Scheme administrators will be jointly and severally liable with the member to the unauthorised payments charge due in respect of a top-up payment. This is a new liability for scheme administrators, making them equally responsible for paying the tax. This means they can deduct it from the top-up payment without the direct consent of the member, which is needed under the mandating procedure.

When making a top-up unauthorised payment, before paying the balance to the member, the scheme administrator must deduct the amount of unauthorised payments charge due after offsetting. If they do not do this, the amount of the unauthorised payments charge, and scheme sanction charge due in respect of the payment will be increased. It will be increased by five-thirds of the difference between the amount of the top-up unauthorised payment paid to the individual and the amount that would have been paid to the individual if tax had been deducted correctly.

Where a top-up unauthorised payment is made, the scheme administrator is responsible for calculating the repayment interest due on recovery of the overpaid tax. Repayment interest is the interest that is paid to a taxpayer on overpaid tax that is repaid to them. The rate of interest payable is set by legislation.

Where the historic payment was made before 6 April 2019, the amount of repayment interest due is limited so that the amount of the overpaid tax plus the repayment interest in respect of the tax charge cannot be more than the new tax charge due in respect of the top-up unauthorised payment.

As set out in step 12 of Appendix B to the public service pensions remedy newsletter � September 2024, in relation to the overpaid unauthorised payments charge (called the excess individual amount under the regulations) interest is calculated for the period ending either:

• 31 January following the end of tax year in which the historic payment was made, or the date of payment if it was made later
• with the date of payment of the top-up unauthorised payment

The regulations also provide that the interest which scheme managers are required to pay on arrears of a benefit that is an unauthorised payment will not be subject to the scheme sanction charge.

In Appendix A you can find further information about the reporting requirements when offsetting or reclaiming overpaid unauthorised payment charges or scheme sanction changes.

Scheme administrators will report any offsetting by spreadsheet in the quarter in which the top up was given. The reporting quarter is aligned to the Accounting for Tax quarters � for example, 1 March 2025 to 30 June 2025. The deadline to report this is 45 days after the quarter end date.

The designated single point of contact (SPOC) for your scheme at HMRC will send you a copy of the template by email. If you have not received it, contact us at [email protected] and include ‘PSPR Event Reportingâ€� in the subject line. We’ll provide you with the spreadsheet template.

You must complete the spreadsheet and return it to HMRC using the Secure Digital Exchange Service.

Split schemes

The Registered Pension Schemes (Splitting of Schemes) Regulations 2006 set out which registered pension schemes are split schemes, how they are split into sub-schemes and who the sub-scheme administrator of each sub-scheme is. They also set out which scheme administrator responsibilities and liabilities sub-scheme administrators take on. Some public service schemes, such as those for police and firefighters, are split schemes.

SI 2023/113, SI 2023/912 and SI 2025/419 are listed as legislation that requires sub-scheme administrators to take on scheme administrator responsibilities and liabilities. However, sub-scheme administrators only become liable to tax as a result of SI 2025/419 once those regulations are in force � on or after 24 April 2025. These changes allow the sub-scheme administrator to operate offsetting and reclaim overpaid tax charges arising as a result of the public service pensions remedy.

Changes consequential to SI 2025/419

Regulation 20 of SI 2023/912 sets out how scheme administrators apply to reclaim overpayments of scheme sanction charge. With one exception, the offsetting and reclaim processes under SI 2025/419 replace those provisions. The exception is where the scheme sanction charge is paid by the scheme administrator of a new scheme (the pension scheme set up by the 2015 reforms) it is treated as paid by the scheme administrator of the relevant legacy scheme (the pension scheme in place before the 2015 reforms).

These regulations also provide for the same deadline (31 January 2031) for immediate choice members or scheme administrators to make an application for repayment of overpaid tax charges.

Lifetime allowance protection application extension

Members who have remediable service under the remedy will have an extended deadline to apply for fixed or individual protection 2016. Generally, individuals must have applied for fixed or individual protection 2016 before 6 April 2025. This deadline is extended to 6 April 2027 for those members with remediable service.

Top-up payments of defined benefits lump sum death benefits

Payments of additional defined benefits lump sum death benefits arising due to the remedy that are paid on or after 6 April 2024 will use up the member’s lump sum and death benefit allowance. It will not be subject to the lifetime allowance rules. If the original lump sum death benefit payment was made in respect of a member aged under 75 and within the ‘relevant 2-year period�, the top-up payment may still be tax-free up to the member’s available lump sum and death benefit allowance.

Scheme pays elections

Regulations 8 and 9 of SI 2023/113 reduce the requirements members have to meet to make a mandatory scheme pays election to their public service pension scheme in relation to annual allowance charges that arise due to the remedy. Similarly, there is a reduction in the information that must be specified in a scheme pays notice in the same circumstances. Members who started to take benefits before 1 October 2023, will have until 5 July 2032 to amend their scheme pays notice relating to annual allowance charges arising from the remedy. Members who had not started to take their pension by that date will have until 5 July 2030.