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Expression of Wish Forms: Advisor Liability and Best Practice Guidance in the Pension IHT Era

· 21 min

Executive Summary

The Finance (No.2) Bill 2025-26, whose pension Inheritance Tax clauses have passed Committee of the Whole House, will bring most unused pension funds and death benefits within the scope of Inheritance Tax from 6 April 2027. This legislative shift transforms expression of wish forms from administrative documents into critical tax-planning instruments. Fidelity platform data indicates that 18% of pension accounts lack any expression of wish form, while 30% of existing nominations predate 2020. With personal representatives assuming liability for reporting and paying IHT on pension death benefits, and potential double taxation reaching effective rates of 67% for beneficiaries of members dying after age 75, the consequences of outdated or absent nominations become materially more severe. This article examines the legal framework governing trustee discretion, analyses Pensions Ombudsman determinations exposing process failures, evaluates the Consumer Duty liability implications for advisors, and provides a structured file review protocol for the transition period.

1. The Legislative Transformation: Pension Death Benefits and Inheritance Tax

The Autumn Budget 2024 announced the government's intention to include unused pension funds and death benefits within the scope of IHT. Draft legislation was published on 21 July 2025, and the Finance (No.2) Bill 2025-26 had its first reading on 2 December 2025.1 The pension IHT provisions, contained in clauses 63 to 68, were debated in the Committee of the Whole House on 12 and 13 January 2026. Clause 63 was agreed and ordered to stand part of the Bill by a vote of 348 to 167, and clauses 64 to 68 were likewise agreed.2 The remainder of the Bill, excluding the pension clauses already dealt with, was committed to a Public Bill Committee with proceedings scheduled for completion by 26 February 2026. The pension IHT provisions are intended to take effect from 6 April 2027.

Scope and Universal Application

The legislation applies IHT to unused pension funds and death benefits "regardless of whether the pension scheme administrators or scheme trustees have discretion over the payment of any death benefits."1 This universal scope eliminates the longstanding distinction that has allowed discretionary pension death benefits to fall outside the estate for IHT purposes. The provision encompasses defined contribution funds in drawdown, uncrystallised funds, and lump sum death benefits payable at the administrator's or trustee's discretion.

The practical significance of this change cannot be overstated. Since the pension freedoms introduced in 2015, defined contribution pension funds have increasingly been used as inter-generational wealth transfer vehicles, with members preserving fund value during their lifetime and relying on discretionary trustee payments to pass assets to beneficiaries outside the IHT estate. The April 2027 provisions close this planning opportunity definitively, regardless of the administrative mechanism through which death benefits are distributed.

The Personal Representative Liability Model

Following the technical consultation that ran from 30 October 2024 to 22 January 2025, the government reversed its original proposed pension scheme administrator-led model. The consultation response confirmed that "overwhelming feedback from respondents about the drawbacks" of the PSA-led approach led to the adoption of a personal representative-led model instead.3 Under this framework, personal representatives rather than pension scheme administrators will be liable for reporting and paying IHT on pension death benefits. A withholding notice mechanism permits personal representatives to direct scheme administrators to withhold up to 50% of taxable benefits for up to 15 months from the date of death to secure IHT payment.1

This liability allocation creates a significant coordination challenge. Personal representatives must identify all pension arrangements held by the deceased, obtain valuations, calculate the IHT due, and issue withholding notices within prescribed timeframes. Where expression of wish forms direct payments to beneficiaries before the personal representative has assessed the IHT position, a funding gap may arise. The Chartered Institute of Taxation has raised concerns about creating personal liability without control, noting that personal representatives will be liable for IHT on pension funds over which they have no direct authority.2

Revenue Projections and Carve-Outs

The government estimates that 10,500 additional estates will face IHT liability annually, with an average IHT increase of approximately GBP 34,000 per affected estate and projected annual revenue of GBP 1.46 billion by 2030.1 Two significant carve-outs are preserved: death in service benefits from registered pension schemes are excluded from IHT regardless of discretionary or non-discretionary structure, and benefits passing to a surviving spouse or civil partner remain exempt.4 Dependant's scheme pensions payable from defined benefit arrangements are also excluded, an important distinction for members retaining defined benefit entitlements alongside defined contribution funds.

Interaction with the Residence-Based IHT Regime

The residence-based IHT regime, enacted from 6 April 2025, replaced the domicile-based system with a 10/20-year long-term resident test and 3-10 year tail provisions.5 For pension holders with cross-border connections, the interaction between the new residence-based regime and the pension IHT provisions creates additional complexity. An individual who has been UK resident for 10 of the previous 20 tax years is treated as a long-term UK resident for IHT purposes, bringing worldwide assets including overseas pension arrangements within scope. Conversely, individuals who leave the UK remain within the IHT net for a tail period of between 3 and 10 years depending on the duration of prior residence. Advisors servicing internationally mobile clients must consider whether the member's residence status at death brings pension assets within the UK IHT charge, adding a further dimension to expression of wish strategy.

The Non-Binding Principle

Expression of wish forms are fundamentally non-binding instruments. As Royal London's technical guidance confirms, the scheme administrator or trustees exercise discretion and are "not required to follow the member's wishes" but "will consider the member's wishes when deciding" on the distribution of death benefits.6 This discretionary mechanism has historically served a dual purpose: providing the member with a means of indicating preferred beneficiaries while maintaining the trustee discretion that kept benefits outside the estate for IHT purposes.

The non-binding nature of expression of wish forms creates a distinctive advisory challenge. Members may assume that completing a form guarantees their intended beneficiary will receive the funds. In practice, trustees must consider the form alongside other factors including the member's family circumstances at the date of death, any dependants, the financial position of potential beneficiaries, and whether the member's circumstances changed after the form was completed. Advisors have a corresponding obligation to ensure that clients understand the distinction between an expression of wish and a binding legal direction.

Binding Versus Discretionary Nominations

Under the current rules, the distinction between binding and discretionary nominations carries material IHT consequences. A binding nomination gives the member "a general power that enables them to dispose of the property," placing benefits within the estate.1 Discretionary nominations, by contrast, preserve the trustee's discretion and keep benefits outside the IHT estate. From April 2027, this distinction becomes irrelevant for IHT purposes, as the legislation applies regardless of the nature of the nomination. However, the distinction retains significance for the exercise of trustee discretion and the speed of benefit distribution. Binding nominations may allow faster payment to beneficiaries, as the trustee has no discretionary decision to make, which may become increasingly important where personal representatives need to coordinate IHT payment with benefit distribution.

Nominee Status and Non-Dependant Beneficiaries

The Taxation of Pensions Act 2014 established nominee status as a critical concept for death benefit flexibility. A nominee is any individual other than a dependant who is nominated by the member.7 Non-dependant non-nominee beneficiaries are restricted to lump sum payments only and cannot access beneficiary drawdown, making expression of wish completion essential for intended non-dependant beneficiaries who wish to receive income over time rather than a single lump sum. HMRC's Pensions Tax Manual confirms nine categories of authorised lump sum death benefits, with scheme trustees retaining discretion over distribution across all categories.8 The inability to access drawdown without nominee status has material tax implications: a lump sum payment to a non-nominee beneficiary after the member's 75th birthday is taxed at the beneficiary's marginal income tax rate in a single tax year, whereas drawdown permits phased income extraction over multiple years, potentially at lower marginal rates.

3. Pensions Ombudsman Determinations: Process Failures and Their Consequences

Pensions Ombudsman determinations provide an increasingly detailed body of precedent on the consequences of process failures in death benefit administration. Three determinations are particularly instructive for advisory practices.

CAS-38697-T1F1: Maladministration Through Procedural Barriers

The Ombudsman found maladministration where a SIPP provider required a deceased member's widow, who was the sole beneficiary named in the expression of wish, to establish a separate SIPP before receiving flexi-access drawdown payments. The provider's own terms and conditions permitted direct payment to a beneficiary's bank account. The determination established that providers cannot impose unnecessary procedural barriers where a valid expression of wish exists and the scheme rules do not mandate the additional steps.9 For advisors, this case underscores the importance of understanding provider-specific processes and challenging administrative requirements that lack contractual or regulatory foundation. Where an advisor becomes aware that a provider is imposing requirements beyond those set out in scheme rules, the Consumer Duty obligation to act in the client's interest may require escalation of the complaint.

PO-22369: Conflict of Interest and Professional Trustee Breach

In PO-22369, the Ombudsman overturned SSAS trustees' distribution of death benefits, finding that member trustees had "a clear and serious conflict of interest" and that the professional trustee, Whitehall, had failed to advise them to obtain independent legal advice. Whitehall was found in breach of section 249A of the Pensions Act 2004.10 This determination is significant because it demonstrates that professional trustees owe duties that extend beyond passive compliance to active governance, including identifying and managing conflicts in the exercise of discretion over death benefits. For advisory firms that recommend or facilitate SSAS arrangements, the case establishes a clear expectation that professional trustees must take proactive steps to ensure that conflicted trustee boards receive appropriate guidance before making distribution decisions.

PO-40022: Informal Communications Are Not Formal Nominations

A deceased member's email to his IFA, written six days before death, expressed wishes for his partner to receive pension benefits. The provider held no formal expression of wish form. The Ombudsman dismissed the partner's complaint, finding that the provider "had acted within its discretion" and was not required to treat the IFA communication as a nomination under scheme rules.11 This determination carries particular weight for advisory practices: it confirms that informal communications, however clear, do not substitute for formal nomination processes. Advisors who receive verbal or written indications of client wishes bear a corresponding responsibility to facilitate the completion of formal documentation without delay. The six-day gap in this case represents a particularly stark illustration of the consequences of procedural delay.

Common Threads and the General Code

Across these determinations and broader Ombudsman case law, several themes emerge. The Pensions Regulator's General Code of Practice, effective from March 2024, reinforces that trustees must follow proper processes when exercising discretion, considering all relevant factors and documenting their reasoning.12 Process compliance, documentation, and the proper exercise of discretion form the core standards against which trustee and provider conduct is assessed. The General Code's requirements on governing body effectiveness and decision-making processes apply equally to death benefit discretion, establishing a governance framework that advisory firms should understand when advising clients on scheme selection and trustee engagement.

4. Advisor Liability Under the Consumer Duty

PRIN 2A Cross-Cutting Rules Applied to Expression of Wish

The FCA Consumer Duty, in force since July 2023, imposes three cross-cutting rules that bear directly on expression of wish processes.13 The requirement to act in good faith (PRIN 2A.2.1R/2.2R) mandates proactive communication about the importance of completing and updating nominations. The obligation to avoid foreseeable harm (PRIN 2A.2.8R/2.9R) means that failing to flag the IHT consequences of absent or outdated nominations may constitute foreseeable harm by omission. The duty to enable and support clients (PRIN 2A.2.14R) extends to facilitating death benefit planning as part of the advice relationship.

The FCA's Finalised Guidance FG22/5 elaborates that the Consumer Duty is "a higher and more exacting standard of conduct" than the principles it replaced.14 Applied to expression of wish processes, this means that a passive approach, waiting for clients to raise nomination questions, falls below the expected standard. The four Consumer Duty outcomes, covering products and services, price and value, consumer understanding, and consumer support, each have direct application to how advisory firms manage death benefit nominations across their client portfolios. The consumer understanding outcome is particularly relevant: firms must ensure that clients understand both the non-binding nature of expression of wish forms and the IHT implications of their nomination choices under the post-April 2027 framework.

The Professional Negligence Framework

A financial advisor's duty of care arises from the contractual relationship and statutory regulatory duties under the FCA regime. A breach occurs where the advisor's conduct fell below the standard expected of a reasonably competent financial professional in comparable circumstances. With the April 2027 changes bringing pension death benefits within IHT, the materiality of expression of wish strategy increases substantially. Where an advisor fails to review and update nominations, and a client's estate incurs avoidable IHT as a consequence, the elements of negligence, namely duty, breach, causation, and quantifiable loss, may be satisfied.

Limitation periods provide a six-year window from the date of the negligent act, or three years from the date of discovery, for claims to be brought. The Court of Appeal's decision in Options UK v FOS [2024] EWCA Civ 541 confirmed the Financial Ombudsman Service's broad approach to complaints resolution, considering "both legal and non-legal standards, including the FCA's Principles for Businesses, contractual principles, statute, regulatory guidance, and best practice."15 This ruling reinforces that best practice standards, including systematic expression of wish review, may inform the assessment of whether an advisor met the requisite standard of care. Advisory firms should note that the FOS can award up to GBP 445,000 for complaints about acts or omissions on or after 1 April 2019 (the maximum applying from 1 April 2025),16 and that complaints may be brought by personal representatives or beneficiaries who suffer loss as a result of inadequate nomination advice.

Compliance Evidence Requirements

Advisory firms should consider documenting expression of wish review conversations as part of the ongoing advice file. Evidence that the advisor raised the topic, explained the IHT implications, and facilitated nomination completion or update provides a robust defence against future complaints. Where a client declines to act on a recommendation to update nominations, recording that decision and the reasons given creates a contemporaneous record of the advisor's discharge of duty. Suitability reports under COBS 9.4 should address death benefit flexibility where relevant to the pension advice, and the suitability assessment under COBS 19.1 for pension transfers must consider how death benefit planning objectives are met by the recommended arrangement.13

5. Strategic Nomination in the Post-2027 Landscape

Spousal Bypass Trust Obsolescence

Spousal bypass trusts have been a widely used strategy, with pension death benefits nominated to discretionary trusts to bypass the surviving spouse's estate for second-death IHT purposes. From April 2027, payments to such trusts will be assessed to IHT and will not benefit from the spousal exemption.17 Where a surviving spouse exists, direct nomination to the spouse or civil partner preserves the spousal exemption and defers IHT to the second death. Advisory firms with clients holding existing trust-based nominations should initiate a systematic review programme, as the tax rationale for these arrangements will be materially undermined. The review should assess whether the trust serves non-tax objectives, such as asset protection in the event of the surviving spouse's remarriage, that may justify its retention despite the loss of IHT efficiency.

The Double Taxation Challenge

Beneficiaries of pension holders dying after age 75 face potential double taxation at effective rates reaching 67%.18 IHT at 40% applies to the full pension fund value, while income tax at the beneficiary's marginal rate applies to subsequent drawdown payments from the remaining 60%. At the additional rate of 45%, the effective combined rate reaches approximately 67%. Consider a pension fund valued at GBP 500,000 at death, where the deceased's nil-rate band (GBP 325,000) and residence nil-rate band (up to GBP 175,000) are exhausted by other estate assets: IHT of GBP 200,000 reduces the available fund to GBP 300,000, from which beneficiary drawdown payments are subject to income tax at the beneficiary's marginal rate. At the additional rate, a further GBP 135,000 is payable, leaving approximately GBP 165,000 of the original GBP 500,000, an effective combined tax rate of 67%.

This calculation, while representing a worst-case scenario where available allowances are absorbed by non-pension estate assets, illustrates why nomination strategy and broader estate planning must be considered in tandem. Advisors should model the tax impact of alternative strategies including accelerated drawdown during the member's lifetime, phased benefit crystallisation, and the use of the spousal exemption to defer tax liabilities. Cashflow modelling becomes essential to quantify the trade-off between maintaining pension fund value for legacy purposes and drawing down during the member's lifetime at potentially lower marginal rates.

The Pre-April 2027 Transition Window

The period between now and April 2027 presents a distinctive planning window. Under current rules, discretionary pension death benefits remain outside the estate for IHT purposes. Advisors should assess whether any clients would benefit from reviewing their nomination strategy during this transition period, taking account of the member's age, health, fund size, existing estate planning, and family circumstances. The targeted support regime, effective from 6 April 2026 following the FCA's policy statement PS25/22, may provide an additional mechanism for platform providers to prompt expression of wish updates for relevant customer segments.19

Multiple Scheme Coordination

Many clients hold pension benefits across multiple schemes, each with separate expression of wish arrangements. A coordinated approach to nomination strategy across all schemes is essential to avoid unintended consequences. Where a client's total pension wealth, combined with other estate assets, exceeds the nil-rate band, the allocation of nominations across schemes may have material IHT implications. Advisors should maintain a consolidated register of each client's pension arrangements and corresponding nomination status, recording the provider, fund value, current nomination, date of last review, and whether the nomination requires updating in light of the April 2027 changes.

6. A Best Practice File Review Protocol

Prioritisation Methodology

Given the scale of the task, with Fidelity data indicating that 18% of accounts lack nominations and 30% hold outdated forms, advisory practices require a structured prioritisation framework.20 A risk-based approach should prioritise clients according to several factors: total pension fund value relative to the nil-rate band and residence nil-rate band; member age and health status; currency of existing nominations, with forms predating 2020 warranting immediate attention; the presence of spousal bypass trust nominations requiring strategic review; and the complexity of family circumstances including blended families, estranged dependants, and non-dependant intended beneficiaries who lack nominee status.

Audit Checklist

For each client, the file review should address four dimensions. First, existence: does a current expression of wish form exist for every pension arrangement held? Second, currency: when was the nomination last reviewed, and have the member's circumstances changed since that date, including marriage, divorce, bereavement, birth of children or grandchildren, or a material change in financial position? Third, completeness: does the nomination reflect the member's current wishes, and are all intended beneficiaries correctly identified with full details including full name, date of birth, and relationship to the member? Fourth, strategic alignment: in light of the April 2027 changes, does the nomination strategy remain tax-efficient, or does it require revision to take advantage of the spousal exemption or to address the double taxation risk?

Annual Review Integration

Expression of wish review should be embedded as a standing agenda item in annual review meetings. The FCA's Consumer Duty framework supports this approach: the obligation to deliver good outcomes throughout the product lifecycle encompasses periodic review of death benefit arrangements. Firms should consider adding expression of wish status to their standard review documentation, creating a systematic prompt that ensures the topic is addressed at each client interaction. A compliance monitoring programme should sample expression of wish documentation as part of the firm's annual file review process, verifying both that the topic is raised and that the client's response is recorded.

Documentation and Evidence Trail

The compliance evidence trail for expression of wish reviews should include: the date the topic was raised; the client's current nominations as recorded; the advisor's recommendation regarding updates, if any; the client's response and decision; confirmation that any requested changes have been submitted to the relevant provider; and follow-up to verify that the provider has processed the update. This documentation serves both the client's interests and the firm's regulatory and professional liability position. Where a client declines to update an expression of wish despite the advisor's recommendation, the file note should record the specific reasons given and confirm that the client was informed of the potential IHT consequences.

Conclusion

The inclusion of pension death benefits within IHT from April 2027, as provided by the Finance (No.2) Bill whose pension clauses have passed Committee of the Whole House, transforms expression of wish forms from administrative formalities into instruments with material tax and estate planning consequences. The convergence of legislative change, Consumer Duty obligations, and an evolving body of Pensions Ombudsman case law creates a new liability landscape for advisory practices.

Firms that implement systematic file review protocols, document their expression of wish conversations, and proactively address the strategic implications of the new regime will both mitigate regulatory and professional negligence risk and deliver demonstrable value to clients during a period of significant legislative change. The transition window before April 2027 represents an opportunity for advisory practices to differentiate through proactive, evidence-based client engagement on a topic that will affect a substantial proportion of pension holders' estates.

The residence-based IHT regime, already in force from April 2025, adds further complexity for clients with cross-border connections, reinforcing the need for advisors to consider expression of wish strategy within the broader context of each client's residence status and estate planning position. As the Bill progresses through Report stage, Third Reading, and the House of Lords, advisory firms should monitor for amendments to the pension IHT provisions and prepare to update their processes accordingly.

CPD Declaration

Estimated Reading Time: 18 minutes Technical Level: Advanced Practice Areas: Pension Planning, Estate Planning, Regulatory Compliance, Consumer Duty

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the key provisions of the Finance (No.2) Bill 2025-26 relating to the inclusion of pension death benefits within Inheritance Tax from April 2027, including the personal representative liability model and withholding notice mechanism
  2. Explain how the FCA Consumer Duty cross-cutting rules under PRIN 2A create new obligations for advisors regarding expression of wish review, documentation, and proactive client communication
  3. Analyse the liability implications established by Pensions Ombudsman determinations CAS-38697-T1F1, PO-22369, and PO-40022 for advisory process design and provider engagement
  4. Evaluate the tax efficiency of direct spousal nomination versus spousal bypass trust nomination under the post-April 2027 IHT framework, including the double taxation risk for post-75 deaths
  5. Design a risk-based file review protocol for prioritising expression of wish updates across a client portfolio, incorporating the four-dimension audit framework

Regulatory Competency Mapping

  • FCA COBS 9.4: Suitability assessment including death benefit flexibility
  • FCA PRIN 2A: Consumer Duty obligations including avoiding foreseeable harm by omission
  • TPR General Code of Practice: Trustee governance and proper exercise of discretion

Reflective Questions

  1. How would you prioritise your client book for expression of wish reviews given the April 2027 deadline, and what criteria would determine high-risk cases requiring immediate attention?
  2. What changes to your firm's annual review process would be needed to embed systematic expression of wish documentation as a Consumer Duty compliance measure, and how would you evidence this in your compliance monitoring programme?
  3. How might the interaction between the residence-based IHT regime and the pension death benefit provisions affect your advice to internationally mobile clients holding UK pension arrangements?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-04. The Finance (No.2) Bill 2025-26 is currently before Parliament and its provisions may be amended before enactment. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. GOV.UK - Inheritance Tax on unused pension funds and death benefits (Policy Paper, July 2025). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-on-unused-pension-funds-and-death-benefits ↩ ↩2 ↩3 ↩4 ↩5

  2. UK Parliament - Finance (No. 2) Bill 2024-26 (Bill Progress Tracker). https://bills.parliament.uk/bills/4042 ↩ ↩2

  3. GOV.UK - IHT on pensions: liability, reporting and payment - Summary of responses (July 2025). https://www.gov.uk/government/consultations/inheritance-tax-on-pensions-liability-reporting-and-payment/outcome/inheritance-tax-on-pensions-liability-reporting-and-payment-summary-of-responses ↩

  4. GOV.UK - Tax on a private pension you inherit. https://www.gov.uk/tax-on-pension-death-benefits ↩

  5. GOV.UK - Inheritance Tax: residence-based regime (Finance Act 2025). https://www.gov.uk/government/publications/inheritance-tax-residence-based-regime ↩

  6. Royal London - Death benefits: nominate a beneficiary (Technical Central, 2025). https://adviser.royallondon.com/technical-central/pensions/death-benefits/death-benefits-discretion-and-how-to-nominate-a-beneficiary/ ↩

  7. Taxation of Pensions Act 2014 - Explanatory Notes. https://www.legislation.gov.uk/ukpga/2014/30/notes/division/6/6 ↩

  8. HMRC Pensions Tax Manual PTM071000 - Death Benefits Essential Principles. https://www.gov.uk/hmrc-internal-manuals/pensions-tax-manual/ptm071000 ↩

  9. Pensions Ombudsman - CAS-38697-T1F1: Curtis Banks Universal SIPP (December 2024). https://www.pensions-ombudsman.org.uk/decision/2024/cas-38697-t1f1/curtis-banks-universal-sipp-cas-38697-t1f1 ↩

  10. Pensions Ombudsman - PO-22369: Allen, Allen & Ms E SSAS (December 2022). https://www.pensions-ombudsman.org.uk/decision/2022/po-22369/allen-allen-ms-e-ssas-po-22369 ↩

  11. Addleshaw Goddard - Scheme entitled not to treat member's email as expression of wish (PO-40022, 2020). https://www.addleshawgoddard.com/en/insights/insights-briefings/2020/pensions/trustee-quarterly-update-december-2020/scheme-entitled-not-to-treat-members-e-mail-received-after-death-as-expression-of-wish-form/ ↩

  12. TPR - General Code of Practice (March 2024). https://www.thepensionsregulator.gov.uk/-/media/thepensionsregulator/files/import/pdf/general-code-of-practice.ashx ↩

  13. FCA Handbook - PRIN 2A The Consumer Duty. https://handbook.fca.org.uk/handbook/prin2a ↩ ↩2

  14. FCA Finalised Guidance FG22/5 (July 2022). https://www.fca.org.uk/publication/finalised-guidance/fg22-5.pdf ↩

  15. Herbert Smith Freehills - Options UK v FOS [2024] EWCA Civ 541. https://www.hsfkramer.com/notes/publiclaw/2024-posts/fairness-over-formulas-the-financial-ombudsmans-approach-to-complaints ↩

  16. Financial Ombudsman Service - Award limits (2025-26). https://www.financial-ombudsman.org.uk/consumers/expect/compensation ↩

  17. Aviva - April 2027: Retirement, death, and spousal bypass trusts. https://connect.avivab2b.co.uk/adviser/articles/news/platform-and-investments/april-2027-is-coming-what-professionals-need-to-know-about-retir/ ↩

  18. GOV.UK - Inheritance Tax on unused pension funds and death benefits (Double taxation analysis). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-on-unused-pension-funds-and-death-benefits ↩

  19. FCA - PS25/22: Supporting Consumers' Pensions and Investment Decisions (December 2025). https://www.fca.org.uk/publications/policy-statements/ps25-22-consumer-pensions-investment-decisions-rules-targeted-support ↩

  20. Fidelity Adviser Solutions - Pensions and IHT: should clients' Expression of Wish be updated now? (June 2025). https://adviserservices.fidelity.co.uk/news-insights/financial-advisor-insights/insights-and-opinions/pensions-and-iht-should-clients-expression-of-wish-be-updated-now/ ↩

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