PTM161100 - Information and administration: the event report: essential principles
Glossary PTM000001
What is the Event Report?
Reportable fund movements
Reportable changes
Submitting the Event Report
When the Event Report must be submitted
What happens if the Event Report is late or inaccurate
How the Event Report must be submitted
Section 251 Finance Act 2004
Regulations 3 & 4 The Registered Pension Schemes (Provision of Information) Regulations 2006 - SI 2006/567
The guidance on this page is about how a scheme administrator gives information to HMRC about certain events – ‘reportable events’ – that occur during a tax year and in particular whether information about one or more such reportable events occurring in a tax year is to be provided via a single report for that year, called the ‘Event Report’ or provided in another way.
The term ‘Event Report’ is used here to mean the name given to the HMRC online process for submitting information about certain reportable events.
For a summary of the scheme administrator information obligations, including information provided to HMRC whether via the Event Report or otherwise, see PTM160300.
What is the Event Report?
The scheme administrator of a registered pension scheme must tell HMRC when certain reportable events occur. For the majority of reportable events, this is done by submitting the Event Report for a tax year.
These reportable events are split into two broad categories:
- reportable changes, and
- reportable fund movements.
The number of reportable events has changed over time as has the definition of what has to be reported. The table below shows which reportable events apply for which tax year.
The numbering of the reportable events in the table below correlates with the reportable events listed in regulation 3 of the Registered Pension Schemes (Provision of Information) Regulations 2006 and those reportable events comprise most of the events to be reported via the Event Report process.
Information about reportable events 9 and 20A is provided separately from the Event Report process.
Also included as a reportable event for the purpose of the Event Report process, but not included in the list of reportable events in the table below, is the reporting of the completion of winding up of a pension scheme. Such an event is reportable but under regulation 4 of the Registered Pension Schemes (Provision of Information) Regulations 2006 rather than regulation 3 of the same regulations.
| Reportable event | 2015-16 to 2017-18 | 2018-19 to 2023-24 | 2024-25 onwards |
|---|---|---|---|
| 1 | Yes | Yes | Yes |
| 2 | Yes | Yes | No |
| 3 | Yes | Yes | Yes |
| 4 | Yes | Yes | Yes |
| 5 | Yes | Yes | Yes |
| 6 | Yes | Yes | No |
| 7 | Yes | Yes | No |
| 8 | Yes | Yes | No |
| 8A | Yes | Yes | No |
| 9 | Yes | Yes | Yes |
| 10 | Yes | Yes | Yes |
| 11 | Yes | Yes | Yes |
| 12 | Yes | Yes | Yes |
| 13 | Yes | Yes | Yes |
| 14 | Yes | Yes | Yes |
| 15 | No | No | No |
| 16 | No | No | No |
| 17 | No | No | No |
| 18 | Yes | Yes | Yes |
| 19 | Yes | Yes | Yes |
| 20 | Yes | Yes | Yes |
| 20A | No | Yes | Yes |
| 21 | No | No | No |
| 22 | Yes | Yes | Yes |
| 23 | Yes | Yes | Yes |
| 24 | No | No | Yes |
Guidance on reportable events for years prior to 6 April 2015 can be found in previous versions of the Pensions Tax Manual held on the National Archives website and archived versions of the Registered Pension Schemes Manual (RPSM), also held on the National Archives website.
Reportable fund movements
Reportable fund movements relate mainly to payments made by a registered pension scheme with the exception being those relating to scheme chargeable payments and annual allowance. The reportable events that fall into the reportable fund movements category are:
1: Unauthorised payments
2: Payments exceeding 50% of the standard lifetime allowance (up to and including the 2023-24 tax year)
3: Early provision of benefits
4: Serious ill-health lump sum
5: Cessation of ill-health pension
6: Benefit crystallisation events and enhanced lifetime allowance, enhanced protection, fixed protection, fixed protection 2014, fixed protection 2016, individual protection 2014 or individual protection 2016 (up to and including the 2023-24 tax year)
7: Pension commencement lump sum (up to and including the 2023-24 tax year)
8: Pension commencement lump sum: primary and enhanced protection (up to and including the 2023-24 tax year)
8A: Stand-alone lump sum (up to and including the 2023-24 tax year)
9: Transfers to qualifying recognised overseas pension schemes
15: Alternatively secured pension (up to 2010 to 2011)
16: Transfer lump sum death benefit (up to 2007 to 2008)
17: Lump sum payment after the death of a member aged 75 or over (up to 2010 to 2011)
18: Scheme chargeable payment
21: Flexible drawdown arrangements (up to 2014 to 2015)
22: Annual Allowance
23: Dual annual allowances.
24. Payments of lump sum and lump sum death benefits in excess of the allowances in relation to relevant benefit crystallisation events
Scheme administrators do not need to report an event relating to a member who was not a relevant UK individual whilst they were an active member of the registered pension scheme. Guidance on reportable fund movements can be found at:
- Events 1 to 5 -PTM161300
- Events 6 and 7 - PTM161400
- Events 8 to 9 - PTM161500
- Event 18 - PTM161600
- Event 21 to 23 - PTM161600
- Event 24 - PTM161800
Guidance on reportable events for tax years before 2011 to 2012 can be found in an archived version of the RPSM held on the National Archives website.
Reportable changes
Reportable changes are events that relate to changes in the details about the registered pension scheme. The reportable events that fall into this category are:
10: Investment-regulated pension scheme
11: Changes in scheme rules
12: Changes to rules of a scheme treated as more than one scheme pre A-day
13: Change in legal structure of scheme
14: Change in number of members
19: Country or territory of establishment
20: Occupational pension scheme
20A: Master Trust scheme.
Guidance on reportable changes can be found at PTM161700.
Also included as a reportable change event is the completion of winding up of the pension scheme (see PTM168000).
Guidance on reportable events for tax years before 2011 to 2012 can be found in an archived version of RPSM held on the National Archives website.
Submitting the Event Report
Regulation 3(1) The Registered Pension Schemes (Provision of Information) Regulations 2006- SI 2006/567
The scheme administrator is responsible for filing the Event Report and ensuring it is accurate and complete. Where a scheme has been de-registered then the person (or persons) who was the scheme administrator immediately before the scheme was de-registered is responsible for filing the Event Report.
A practitioner can file the Event Report on behalf of the scheme administrator, but the scheme administrator remains responsible for ensuring that it is submitted on time and the contents are correct. Where a practitioner submits the report the scheme administrator should have seen and approved the content of the Event Report before it is submitted to HMRC. The practitioner must make a declaration that the scheme administrator has approved the contents before they can submit it to HMRC.
The scheme administrator is liable for penalties if the Event Report is incomplete or inaccurate, including where they ask a practitioner to submit the report on their behalf.
The Registered Pension Schemes (Splitting of Schemes) Regulations 2006 - SI 2006/569
Where the registered pension scheme is a split scheme the sub-scheme administrator is responsible for filing the Event Report due for their sub-scheme. The Registered Pension Schemes (Splitting of Schemes) Regulations 2006 specifies which schemes are split schemes, how they are split into sub-schemes and who the sub- scheme administrator is.
When the Event Report must be submitted
HMRC will not send a notice telling the scheme administrators that an Event Report needs to be submitted. If a pension scheme is registered and a reportable event has occurred in the tax year an Event Report must be submitted. If no reportable events have occurred in the tax year the scheme administrator does not need to send in an Event Report.
Rather than an Event Report a relevant form must, instead, be submitted in the case of the following reportable events:
- transferring to a qualifying recognised overseas pension scheme that were requested by the member after 5 April 2012
- a pension scheme becoming or ceasing to be a Master Trust scheme.
If no reportable events have occurred in the tax year the scheme administrator does not need to send in an Event Report (or relevant form).
MRC must receive the Event Report by 31 January after the end of the tax year to which the Event Report relates. Unless the registered pension scheme has wound up the Event Report cannot be filed before the end of the tax year.
If the Event Report is for the tax year ended 5 April 2014 the Event Report can be filed in the period 6 April 2014 to 31 January 2015. Where an Event Report is submitted late penalties may apply.
If a registered pension scheme has wound up, the deadline for filing the Event Report becomes the earlier of:
- 3 months after the scheme completed winding up
- 31 January after the end of the tax year to which the Event Report relates.
So, if a scheme had events to report for the 2020 to 2021 tax year, and the scheme wound up on 1 June 2021, the 2020 to 2021 Event Report should be filed by 31 August 2021. An Event Report for 2021 to 2022 (to cover the scheme wind-up) will also need to be filed by 31 August 2021.
There is a different deadline for reporting:
- transfers to a qualifying recognised overseas pension scheme that were requested by the member after 5 April 2012 - see PTM103050
- becoming or ceasing to be a Master Trust scheme; this should be reported within 30 days of the event.
What happens if the Event Report is late or inaccurate
Section 98 Taxes Management Act 1970
If the Event Report is not filed on time the scheme administrator will be liable to a penalty of up to £300. Further penalties may be due where the Event Report still hasn’t been sent in after this penalty has been raised. The further penalty can currently be up to £60 for every day that the Event Report is late. As soon as the Event Report is correctly filed no more extra daily penalties can be raised.
If the information in the Event Report is not correct the scheme administrator can be liable to a penalty for fraudulently or negligently making an incorrect return. This penalty can be up to £3,000.
Scheme administrators can appeal against a penalty using form APSS413.
How the Event Report must be submitted
Regulations 4 and 6 The Registered Pension Schemes and Overseas Pension Schemes (Electronic Communication of Returns and Information) Regulations 2006 - SI 2006/570
With the exception of reporting:
- transfers to a qualifying recognised overseas pension scheme that were requested by the member after 5 April 2012
- becoming or ceasing to be a Master Trust scheme
the Event Report must be delivered electronically.
For an Event Report for 2023 to 2024, or a later tax year, the scheme administrator must use HMRC's Managing Pension Schemes service to make the electronic delivery.
For an Event Report for 2022 to 2023, or an earlier tax year, HMRC's Pension Schemes Online must be used.
The scheme administrator will not have met their obligation to file an Event Report until submission has been accepted by (depending on which system must be used) the Managing Pension Schemes service or Pension Schemes Online.
The legislation treats any paper Event Reports as not having been delivered.
There is a different process for reporting transfers to a qualifying recognised overseas pension scheme, where the transfer was requested after 5 April 2012. These transfers must be reported using form APSS262 - Transferring UK tax-relieved pension assets - within 60 days of the transfer.
Only one Event Report per scheme per year can be submitted. The Guide to using the Online Service for scheme administrators and practitioners sets out the practical steps of filing an Event Report.
It is possible to compile the Event Report throughout the year and save it. However, HMRC cannot see the content of an Event Report that has been compiled and saved, but not submitted. The Event Report must be submitted to meet the scheme administrator’s filing obligations. Just compiling, but not submitting an Event Report does not meet the obligation to file.
Once the Event Report has been submitted, any changes that need to be made to it will be an amendment. After an Event Report has been submitted to HMRC, it can be amended using the Managing Pension Schemes service or Pension Schemes Online (depending on which system was used to submit the Event Report) but there is a need to wait for 24 hours after the Event Report has been submitted before amendments can be made to that Event Report.