HMRC directs pension members aged 16+ without NI numbers to apply

HMRC now tells pension scheme members aged 16 or over who do not have a National Insurance number to apply for one when their scheme administrator is checking residency status for relief at sourceGOV. The previous instruction covered members over 16GOV and told administrators to ask them to contact the National Insurance Helpdesk. Administrators must continue using ‘rest of UK’ residency status for these membersGOV.

The change concerns HMRC’s residency-checking instructions. The statutory member-information rule allows a National Insurance number or a statement that the individual does not have one, with exceptions for under-16s and non-UK citizens who are not UK-resident. The annual-return rule similarly permits a number or the reason the member has none, subject to those exceptions. The application instruction should therefore be distinguished from the information that schemes are required to collect and report.

HMRC also gives instructions for members without a residency status result. Where the annual report or lookup service does not provide the expected residency result, HMRC says to check the member’s details. If those details appear correct, the member should contact National Insurance enquiries. The lookup requires the member’s first and last name, National Insurance number and date of birth.

HMRC’s separate application guidance sets out eligibility: applicants must live in the UK, have the right to work there and be working, looking for work or have a job offer. For 16-to-19-year-olds who did not receive a number, it says to check whether one already exists if a parent or guardian completed a Child Benefit claim, or apply online if they did not. Someone who already has a number should find it rather than apply again; the number remains the same for life.

If an administrator does not have a residency status for a member when claiming relief at source on their first contribution, HMRC requires ‘rest of UK’ residency statusGOV. Once a residency status has been used for a claim, the administrator must retain it for the whole tax year, even if a later search gives a different result. HMRC recommends keeping the results page.

Annual residency reports remain available each January for the next tax year and must be downloaded within 144 hours, or six days, of availability. The revised instructions direct administrators to Transfer files securely with HMRC and retain email contact for corrupt files or missed downloads.

The member-information basis is regulation 4 of the Registered Pension Schemes (Relief at Source) Regulations 2005 and regulation 15A, inserted by the Registered Pension Schemes (Relief at Source) (Amendment) Regulations 2018.