HMRC QROPS list- Suspended


The HMRC QROPS list is to be suspended on 1st June 2017, further to an update on the HMRC website


The HMRC QROPS list suspension will be until 5th June 2017 and no reason has been given. Schemes that wish to remain on the HMRC QROPS list must confirm that they meet the new regulatory requirements by 1st June and that the requirements were in force as at 6th April 2017.

From the date of the new HMRC QROPS list, there must be a system of personal pension regulation in the jurisdiction where the QROPS is based.

One of the assumptions is that HMRC require time to check the schemes all comply. There has been a suggestion of a cull, but that is speculation that may or may not be true.  However, given that a cull is possible, is it a good time to transfer to a QROPS at the moment?

New Regulatory Requirement-HMRC QROPS List

The suspension coincides with the new regulatory requirements and HMRC’s  website  states…..

New regulatory requirements test

Currently if there is a regulator of the type of pension scheme in the country or territory in which the scheme is established, the scheme must be regulated by that regulatory body. If the scheme is not regulated it can’t be an overseas pension scheme.

If there is not a body that regulates pension schemes, a scheme can still be an overseas pension scheme if one of the following applies:

  • it is established in a EU member state (other than the UK), Norway, Liechtenstein or Iceland
  • the scheme rules require that at least 70% of the member’s UK tax-relieved funds will be used to provide them with an income for life

From 6 April 2017 how a scheme satisfies (passes) the regulatory requirements test will depend on whether or not it is an occupational pension scheme.

Summary HMRC QROPS List

To continue our historical theme, further to our blog referring to the riddle of The Sphinx , I would compare the suspension of the HMRC QROPS list to Aesop’s fable about the fox and the goat. From this fable came the everyday phrase, “look before you leap”

Until the new HMRC QROPS list is released, one may be best advised not to start the transfer of a UK pension without being sure what is on the other side of 5th June.


The views expressed in this article are not to be construed as personal advice. You should contact a qualified and ideally regulated adviser in order to obtain up to date personal advice with regard to your own personal circumstances. If you do not then you are acting under your own authority and deemed “execution only”. The author does not except any liability for people acting without personalised advice, who base a decision on views expressed in this generic article. Where this article is dated then it is based on legislation as of the date. Legislation changes but articles are rarely updated, although sometimes a new article is written; so, please check for later articles or changes in legislation on official government websites, as this article should not be relied on in isolation.

This article was published on 25th April 2017


Chris Lean

Chris is a Chartered Financial Planner who writes blogs and articles to simplify and explain some of the financial issues that affect UK expats. Subjects include; hot topics, regulation and the ever-changing world of finance.

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