SSAS pension HMRC rules: HMRC registers the scheme and applies its tax rules, The Pensions Regulator registers the trustees, and the FCA does not regulate it.
Are SSAS pensions regulated, and by whom?
Several bodies oversee a SSAS, and none covers all of it. HMRC decides whether the scheme is registered, and "A pension scheme must be registered with HMRC to benefit from the tax reliefs available to pensions." Registration is done by the scheme administrator, the person who answers to HMRC for the scheme; setting one up covers the steps.
A company director weighing up a SSAS will want to know which of these duties would sit with its trustees; an FCA-authorised adviser, reached by a free call-back once a name goes into the form on this page, can lay them out for the board.
The Pensions Regulator (TPR) is the second layer. MoneyHelper says SSAS trustees will usually need to register with TPR as well as the scheme with HMRC, and TPR's own page says workplace pensions registered with HMRC "must be registered with us if they have more than one member". TPR later sends a scheme return by notice; for a defined contribution scheme with 2 to 11 members, TPR's current guide is once every three years.
The Financial Conduct Authority is the missing layer. MoneyHelper's SSAS guide, in a copy archived on 15 October 2025, puts it plainly: "As SSAS pensions are not regulated by the Financial Conduct Authority (FCA), scammers will often use them to access scam investments." Warning signs are in pension scams, and who runs a SSAS day to day is explained in SSAS trustees.
What does a SSAS have to report to HMRC?
The scheme administrator is responsible for three kinds of report, all now made on HMRC's Managing Pension Schemes service. HMRC says the administrator can delegate these tasks, but "you remain responsible for making sure they’re accurate and complete."
| Report | What it covers | When it is due |
|---|---|---|
| Event Report | Certain events in the scheme, such as an unauthorised payment or a change in the scheme's rules | By 31 January after the tax year ends; within 3 months if the scheme is wound up. Late: a penalty of up to £300 may be charged, and daily penalties of up to £60 may follow |
| Accounting for Tax return | Tax charges the scheme triggers, such as the 25% authorised surplus payments charge or the 45% special lump sum death benefit charge | Quarterly: 15 May, 14 August, 14 November and 14 February, with the tax |
| Pension scheme return | Information HMRC asks for by sending a notice | The deadline in HMRC's notice. Late: a £100 penalty, plus possible daily penalties of £60 |
The pension scheme return is easy to confuse with TPR's. HMRC says: "This pension scheme return is different from the scheme return for The Pensions Regulator and form SA970 Tax Return for Trustees of Registered Pension Schemes." A trustee can therefore receive two separate returns, from two regulators, with different deadlines. For tax years from 2024 to 2025, HMRC's pension scheme return goes through the Managing Pension Schemes service; HMRC's page was last updated on 15 December 2025.
Which events go on an Event Report is listed in HMRC's guidance. Two on that list that a small scheme can meet are an unauthorised payment (event 1) and a move between HMRC's membership bands at the end of a tax year (event 14), where 2 to 11 members is one band and 12 to 50 the next. Rule and structure changes are in the questions further down.
Which SSAS payments are authorised, and which are not?
HMRC's test is simple to state. In the Pensions Tax Manual, "Any payment that doesn't meet these conditions is an unauthorised payment." The manual splits these into unauthorised member payments and unauthorised employer payments, and adds that "the member or former member does not have to receive the payment for it to be an unauthorised member payment". A payment to some other person or to another pension scheme can still count, and an employer can be charged on a payment made to a connected individual or company. A common example given for members is a distribution before minimum pension age, other than for serious ill-health or an authorised refund of contributions.
The charges stack up. The unauthorised payments charge is a flat 40% of the amount. A further 15% surcharge applies, generally where the unauthorised payments made within 12 months come to a quarter or more of the person's pension rights, lifting the member's tax to 55%. The scheme administrator can also face a scheme sanction charge of 40%, reduced by credit for any unauthorised payments charge actually paid (not the surcharge), but never below 15% of the payment. HMRC's manual puts the effective total at 55% where that charge arises, made up of the member's 40% and the scheme's 15%, and says the 15% surcharge may come on top. In HMRC's worked example, a member whose £20,000 of unauthorised payments reaches the surcharge threshold pays £11,000 in tax.
Whether a particular withdrawal, loan or purchase falls on the wrong side of that line turns on the facts. Holding a proposed loan or purchase up against HMRC's conditions is a job for the FCA-authorised adviser who phones SSAS trustees, at no cost, after they book through the form on this page.
Lending to your own company: when a loan turns unauthorised
A SSAS can lend to the company that sponsors it, which is one of the freedoms people look at it for. HMRC's manual says a loan to a sponsoring employer is an authorised payment only if it passes five tests, covering the security held, the interest charged, how long the loan runs, how large it is and how it is repaid. Fail one and an unauthorised payment arises. Where a loan fails more than one test, the unauthorised payment is the greatest amount worked out under any single test, and it cannot exceed the loan when it was made.
The manual adds that loans must be genuine investments: "They should be prudent, secure and on a commercial basis." A loan to a member, or to someone connected to a member, is taxed as an unauthorised payment, so members cannot lend the fund's money to themselves without that tax charge. How each test works, with the figures, is set out in SIPP vs SSAS, and borrowing against a pension in general is in borrowing against a pension.
Common queries about SSAS and the taxman
What happens if a SSAS is not registered with HMRC?
HMRC's registration guidance says that until it confirms registration, a transfer received from another registered pension scheme is an unauthorised payment, so moving an existing pension in comes after registration, not before. Contributions paid in before then get no tax relief either, as setting up a SSAS explains.
Where do HMRC's SSAS rules sit?
HMRC publishes its guidance for registered pension schemes in the online Pensions Tax Manual. It names the SSAS as one example of a scheme where the member can direct the investments. Whether a specific investment is allowed is for the trustees and their adviser to check against it.
Which changes to a SSAS have to be reported to HMRC?
On HMRC's Event Report list are a change to the scheme's rules that requires an unauthorised payment or allows investments other than insurance policies (event 11), a change to the scheme's structure (event 13), a change of country of establishment (event 19), and the scheme becoming or ceasing to be an occupational pension scheme (event 20). Winding the scheme up is reported on the Event Report too.
Is there a register of SSAS pensions?
HMRC's registration certificate confirms the date of registration and the scheme's Pension Scheme Tax Reference (PSTR), and registration with TPR is a separate step. How much of either record is open to public view is something the adviser on a call-back can clear up, at no charge.
Before a SSAS decision goes further
A SSAS puts the tax duties on the people who run it, so the rules above are worth understanding before a trust deed is signed. Trustees-to-be who send their details with the form on this page are phoned by an FCA-authorised adviser, free, to go through how the reporting and payment rules fit their plans.
Sources: HMRC Pensions Tax Manual (PTM121000, PTM123100, PTM123200, PTM132000, PTM134100, PTM135100); GOV.UK, Send pension scheme reports (last updated 15 December 2025) and Apply to register a pension scheme (last updated 9 July 2025); TPR's registration and scheme return pages (registration page published 29 September 2023); MoneyHelper, SSAS guide (archived 15 October 2025); read 27 October 2026 unless stated.