This guide is for financial advisers only. It mustn’t be distributed to, or relied on by, customers. It is based on our understanding of legislation as at May 2023.
The standard lifetime allowance (SLA) reduced from £1.25m to £1m on 6 April 2016. Two fund protection options were introduced to offer some transitional protection for people who think they will be affected by the SLA reduction. These are fixed protection 2016 (FP2016) and individual protection 2016 (IP2016). This section looks at the IP2016 option. FP2016 is covered in a separate section of this article
IP2016 is only an option for those with pension savings (including any pensions already in payment) of more than £1m on 5 April 2016.
People who apply for IP2016 will be given a protected lifetime allowance equal to the lower of:
The protected lifetime allowance will be quoted as a monetary amount and won’t change over time. If the SLA increases above the protected amount, the IP2016 protection would cease to apply and the higher SLA will become relevant.
It is possible for those with IP2016 to make further pension contributions or accrue additional defined benefit rights after 5 April 2016. However, these additional pension savings are likely to be subject to a lifetime allowance charge when benefits are taken if they exceed an individual’s protected lifetime allowance (or the SLA, if higher).
IP2016 is available for someone:
- with total pension savings on 5 April 2016 valued at more than £1m.
- with no existing fund protection.
- as a back-up to enhanced protection where primary protection or individual protection 2014 isn’t already held as a back-up.
- as a back-up to fixed protection 2012 or 2014 where individual protection 2014 isn’t already held as a back-up.
- as a back-up to fixed protection 2016.
In other words, it’s not available if someone has:
- primary protection.
- enhanced protection with primary protection as a back-up.
- enhanced protection with individual protection 2014 as a back-up.
- fixed protection 2012 with individual protection 2014 as a back-up.
- fixed protection 2014 with individual protection 2014 as a back-up.
If IP2016 is held as a back-up to enhanced protection or one of the fixed protection options, the enhanced or fixed protection will take precedence. If either enhanced protection or fixed protection is lost, IP2016 will apply. It is only possible to have IP2016 as a back-up where the value of benefits at 5 April 2016 was more than £1m.
When an individual takes their benefits, they will be tested against their IP2016 protected amount rather than the SLA at the time, and the amount crystallised will be recorded as a percentage of the protected lifetime allowance. If no tax-free cash protection applies, the maximum tax-free cash available should be calculated as the lower of:
- 25% of the protected lifetime allowance, and
- 25% of the remaining fund.
IP2016 takes effect from:
- 6 April 2016, or
- the date that IP2016 becomes active if it was held as a back-up to enhanced protection or one of the fixed protection options and that fund protection is lost.
To expand, where not held as back up, IP2016 takes effect from 6 April 2016 irrespective of the date that it’s actually granted. As a result, there could be situations where a benefit crystallisation event (BCE) has taken place on or after 6 April 2016 and before IP2016 has been granted. Where the BCE was tested against the SLA rather than the IP2016 protected amount, it is possible to re-visit the BCE to recalculate the figures based on the protected amount under IP2016.
The IP2016 option could be of benefit to:
- anyone who wouldn’t receive another form of benefit from their employer if they had chosen to opt out of any further pension saving or benefit accrual after 5 April 2016. If their employer wasn’t willing to offer an alternative benefit, such as higher pay, then it may be better for any employer contributions or benefit accrual to continue to be made, even though any additional pension savings could be subject to a lifetime allowance charge when benefits are eventually taken.
- anyone who wants to continue making further pension savings after 5 April 2016, even though they may receive a protected lifetime allowance lower than the £1.25m lifetime allowance available through FP2016, and could incur a lifetime allowance charge on the additional savings or benefit accrual.
The value of pension savings at 5 April 2016 can be split into four different categories:
• pensions that someone was receiving before 6 April 2006.
• pensions put into payment after 5 April 2006 but before 6 April 2016 along with certain tax-free lump sums received in the same period.
• uncrystallised funds.
• pension savings in certain overseas pension schemes.
Different valuation methods apply to each different category and more information on each method can be found here. The total value of all pension savings at 5 April 2016 across all four categories will be the amount protected under IP2016.
Please note providers were only required under legislation to provide valuations at 5 April 2016 for up to four years from that date. Since 6 April 2020, there is no statutory obligation on scheme administrators to provide valuations at 5 April 2016.
If a pension debit is made to comply with a pension sharing order on divorce, a person’s protected lifetime allowance under IP2016 may be reduced or even cease to apply. The onus is on an individual to tell HMRC if they have become subject to a pension debit. HMRC will then either:
- confirm that the protected amount is reduced, or
- revoke IP2016 if the value of an individual’s pension rights following the pension debit fall below £1m at the time the pension sharing order takes effect.
Where a pension debit is made on or after 6 April 2017, the value of the debit is reduced by 5% for each full tax year elapsed between 5 April 2016 and the date of the pension debit. The resulting amount is then deducted from the amount protected under IP2016. It will then be clear whether the IP2016 protected amount will be reduced or if IP2016 will be lost.
Further information about reducing or revoking IP2016 due to a pension debit can be found in HMRC guidance at:
Applications for IP2016 can be made online.
Anyone wanting to use the online service will need to have an HMRC Online Services Account and further information on signing in or creating an account is available in the same link.
No paper protection certificate will be issued by HMRC for IP2016 and no application deadline will exist. However, it would be preferable for individuals to apply to HMRC for IP2016 before they take their pension benefits so that any BCE can be calculated assuming the correct level of lifetime allowance.
Protection reference numbers will be in the format of IP16 followed by ten digits and one letter (e.g., IP161234567890B).
A protection reference number for IP2016 will not be issued by HMRC if it is being applied for as a back-up to enhanced protection or one of the fixed protection options. HMRC will instead inform someone if their application for IP2016 as a back-up has been successful. An IP2016 protection reference number will only subsequently be issued if the other form of fund protection is lost and the IP2016 becomes active.
An online scheme administrator look-up service is available on HMRC’s website here. This allows scheme administrators to check the validity of a protection reference number supplied by a customer or scheme member.
When it was originally introduced, in 2006, the intention was that the SLA would increase each year, but that didn't last long.
Details of the current and historical SLA figures are shown below:
|2020/21 - 2023/24
It was announced at the March 2023 Budget that the Lifetime Allowance would be abolished from 6 April 2024.
Further information on IP2016 can be found in HMRC guidance at: