SSAS pension trustees run the scheme under its trust deed, while the scheme administrator, a distinct role the same people can hold, carries the tax duties owed to HMRC.
Who can be a SSAS pension trustee?
A SSAS is a trust, so it has trustees. The Pensions Regulator's trustee toolkit describes the type as "a trust-based pension scheme designed for a maximum of 11 members who are often directors of the sponsoring employer and who want more control over the investments of their pension scheme." The members themselves can be the trustees, or directors of a company acting as sole trustee; where a company is trustee, the Regulator's expectations apply to every individual who exercises any trustee function for it.
Putting a draft trust deed beside the names of those who would fill the trustee seats is a good use of the no-cost phone call an FCA-authorised adviser offers through the form on this page.
Some people cannot take the role at all. Under section 29 of the Pensions Act 1995 a person is disqualified from being a trustee of a trust scheme if, among other things, they have been convicted of "any offence involving dishonesty or deception" (unless the conviction is spent), are an undischarged bankrupt, or are subject to a company director disqualification order or undertaking. A company is disqualified if any of its directors is. The Regulator may waive a disqualification on application, either generally or for a particular scheme.
The Regulator also expects more of a professional trustee, who "should be able to demonstrate a greater level of knowledge than members without such expertise".
What does a SSAS scheme administrator do?
The scheme administrator is a different role from the trustees. HMRC's manual says a registered pension scheme must have one, named under the scheme's rules, so the deed has to allow for the appointment. The post can go to an individual, an employer, a specialist pension administration company, or a mixture. If several people share it, HMRC can look to each for the whole of any tax charge or penalty. Since 6 April 2026 the administrator must be resident in the United Kingdom.
HMRC's list of the administrator's duties includes registering the scheme, paying certain taxes and reporting events to HMRC. The scheme sanction charge, which can follow an unauthorised payment, is among the charges the administrator answers for, and records must be kept for at least six tax years. The reporting detail is in SSAS pension HMRC rules.
Every person making up the administrator must be a "fit and proper person", or HMRC can refuse to register the scheme; it offers no clearance service to confirm anyone's status. Its factors include removal as a trustee by the Regulator or a court, disqualification as a company director, and lacking enough working knowledge of pensions and pensions tax law without employing an adviser who has it.
That last point matters for owner-directors, who "normally do not have a detailed knowledge of pensions and pensions tax legislation", in HMRC's words. Its manual leans on them to bring in a knowledgeable pension practitioner or provider, and a practitioner can be appointed to act for the administrator on some duties.
What do SSAS trustees have to do?
The Regulator's summary is broad: "Your duties are wide-ranging - from the collection of contributions to the investment of assets and payment of benefits." For trustees the statutory knowledge duty covers, its code of practice says they must be familiar with the trust deed and rules, any statement of investment principles and the scheme's administration policies, and must understand pensions and trust law and how assets are invested. Investment values can fall as well as rise, so a scheme can end up with less than was paid in.
Section 247 of the Pensions Act 2004 puts the knowledge duty on every individual trustee of an occupational scheme, but regulations carve out small schemes. The duty does not apply to trustees of a scheme with fewer than twelve members where all the members are trustees and either the scheme provides that decisions are made by unanimous agreement of the member-trustees, or it has a registered independent trustee. A similar exception covers a company that is the sole trustee, where all the members are its directors. Other new trustees get six months of grace from appointment, though not an independent trustee or someone appointed because they held themselves out as an expert. The Regulator's Trustee Toolkit, its free online learning, is open to anyone who wants it anyway.
Decisions follow the deed: under section 32 of the Pensions Act 1995 trustees may decide by majority "unless the scheme provides otherwise", and a deed can require everyone to agree. Exactly how these duties fall between the people on a given board depends on the deed.
Registering the scheme with the Regulator within three months of it first qualifying, and reporting later changes such as a new trustee or a different member count, also fall to the trustees. The first steps are in how to set up a SSAS pension.
Investment brings rules of its own. Outside a small scheme, which is defined by the same membership and unanimity test as the knowledge exemption, regulation 12 of the Occupational Pension Schemes (Investment) Regulations 2005 holds employer-related investments to five per cent of the scheme's resources. How that applies when a SSAS lets a building to the employer is in SSAS commercial property.
SSAS administration: the scheme return, accounts and auditor
A scheme return is completed when the Regulator issues a notice. For a defined contribution scheme "with between two and 11 members" that is currently every three years, and yearly from 12 members, though the Regulator can change the frequency. The Regulator is blunt: "As a trustee, you're responsible for completing the scheme return", and a late return can bring a penalty for a trustee who has not taken all reasonable steps to comply. It suggests having the trust deed and rules and the most recent report and scheme accounts to hand beforehand.
Which of these jobs your own board would carry is something the adviser can help you work out during the call-back that follows your use of the form on this page.
On an auditor, regulation 3 of the Scheme Administration Regulations 1996 disapplies the requirement to appoint one for a scheme with fewer than 12 members where all the members are trustees (or directors of a sole corporate trustee) and decisions are made by unanimous agreement, or a registered independent trustee is in place. For other schemes the requirement stands.
More on SSAS trustees and administrators
Can a company be the trustee of a SSAS?
Yes. The Regulator's code covers "a company acting as trustee of the scheme", and a company is disqualified if any of its directors is.
Can someone who has been bankrupt be a SSAS trustee?
Not while they remain an undischarged bankrupt, or while a bankruptcy restrictions order applies. The Regulator can waive a disqualification if asked, so a past problem is not always final.
Who pays the tax if something goes wrong in a SSAS?
Certain charges, including the scheme sanction charge, are the scheme administrator's to pay. Where there are several administrators, each can be called on for the whole amount. Which charge applies to a particular payment is covered in SSAS and HMRC.
Can a SSAS administrator also be a trustee?
The same people can hold both: HMRC's manual says the administrator may be the employer that set up the scheme or one or more directors of a sponsoring employer. The duties stay separate, and the administrator answers to HMRC for tax and faces its fit and proper test. SIPP vs SSAS shows how this differs from a SIPP, where the provider takes on the running.
Does a SSAS need a professional to run it?
The small-scheme exemptions above can be met by unanimous member decisions instead of a registered independent trustee. Even so, HMRC would expect an owner-director administrator to use an adviser with pensions tax knowledge, and the Regulator expects professional trustees to know more than lay members. Choosing a SSAS provider covers the firms that offer this help.
Before you appoint trustees to a SSAS
Deciding who holds each role before the deed is signed is a topic an FCA-authorised adviser will cover free, on a call you request with the form here.
Sources: The Pensions Regulator (register a scheme, published 29 September 2023; scheme return; trustee toolkit tutorial; understanding your role; knowledge and understanding code, in force 28 March 2024); HMRC Pensions Tax Manual (PTM031200, PTM151000, PTM153000); Pensions Act 1995 ss29, 32; Pensions Act 2004 s247; SI 2006/686 as amended; SI 1996/1715 (auditor exemption); SI 2005/3378 regs 1 and 12; read 27 October 2026 unless stated. Related: what is a SIPP.