HMRC is continuing to look at new ways to combat the threat of pensions liberation. As noted in previous Updates, from September 2014 scheme administrators have had to declare their "fit and proper person" status when they register a pension scheme (HMRC guidance indicates how HMRC will apply this test). The main objective of the new requirements was to make it more difficult to establish and run vehicles for the purposes of pension scams and liberation.

To coincide with the pension changes taking effect in April 2015, HMRC proposes to build upon the existing controls, by requiring scheme administrators to provide HMRC with additional information and declarations online both when a scheme is registered and when it changes its structure or the range or number of members. It is not yet clear what these new requirements will be but the relevant HMRC newsletter can be viewed here.