The transitional period introduced by The Registered Pension Schemes (Modification of the Rules of Existing Schemes) Regulations of 2006 and 2009 ends on 5 April 2011. These regulations:
- allow schemes to continue applying the pre A-day limits to benefits and contributions without changing their scheme rules (the 2006 regulations);
- override any pension scheme rules that require HMRC approval for any changes (the 2009 regulations).
Schemes that relied on these transitional provisions and want to continue to do so after 5 April 2011 must execute necessary amendments to their governing trust deeds by that date. Schemes which already have deeds in place, especially those preserving the old HMRC limits and where schemes intend the transitional provisions to apply after 5 April 2011 should review these to ensure that they actually achieve their objectives and, if they do not, to consider making further amendments.