HMRC will no longer confirm a new scheme's status as a registered pension scheme automatically on submission of the appropriate online form. Instead, more detailed investigations will be undertaken before a scheme's registration is accepted. A key consequence of the change for new schemes is that they will not be able to undertake any activities restricted to registered pension schemes until their registration is confirmed. Hence, any contributions paid in the interim will not attract tax relief and transfers from other registered schemes will be unauthorised payments.

When asked to confirm a receiving scheme's status as a registered pension scheme in connection with a transfer request, HMRC will now only provide this confirmation to the transferring scheme if the receiving scheme is registered and HMRC does not hold information suggesting there is a significant risk the scheme has been set up or is being used to facilitate pension liberation. If either or both of these conditions is not met, HMRC will tell the transferring scheme that this is the case, without seeking consent to do so from the receiving scheme.