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Financial Wellbeing Programs: Including Estate Planning in Total Rewards Strategy

· 20 min

Executive Summary

Employer financial wellbeing programmes overwhelmingly focus on immediate pressures -- budgeting, debt management, savings -- while neglecting estate planning, despite the direct connection between workplace death benefits, pension accumulation, and employees' broader succession needs. The Chartered Institute of Personnel and Development Good Work Index 2025 reports 31% of employees cite money worries as negatively affecting work performance, yet only 20% of organisations systematically assess employee financial wellbeing. From 6 April 2027, the inclusion of unused pension funds within Inheritance Tax estates fundamentally changes this calculus: workplace pension accumulation will carry direct tax consequences that employees may neither understand nor plan for. This article examines the strategic, regulatory, and tax-compliance dimensions of integrating estate planning education into total rewards frameworks, addressing the welfare counselling exemption boundary, benefit-in-kind treatment, and the Financial Conduct Authority advice-guidance distinction.

1. The Financial Wellbeing Case: Beyond Budgeting and Debt

1.1 The Scale of Financial Stress in the Workforce

The evidence base for employer engagement with financial wellbeing is substantial and growing. The CIPD Good Work Index 2025, surveying approximately 5,000 employees with fieldwork conducted in February 2025, found that 31% of employees report money worries negatively affecting their work performance.1 The consequences extend beyond productivity: 19% reported lost sleep due to financial worrying, 15% experienced health problems attributable to financial stress, and 13% found it difficult to concentrate or make decisions at work.1

The Reward and Employee Benefits Association Financial Wellbeing Research 2025 paints an even starker picture: only 29% of employees feel hopeful about their financial situation, a sharp decline from 60% in 2024.2 Among REBA's employer sample -- covering 1.3 million employees -- 67% of reward professionals identify improving workforce health as a strategic financial wellbeing objective, yet REBA's 2024 Financial Wellbeing Research (covering 236 companies) found that 76% cited employees not knowing where to start as a barrier to improving support, and 72% identified a lack of joined-up provision.3

These findings are reinforced by broader sickness absence trends. The CIPD Health and Wellbeing at Work Survey 2025 reports average sickness absence of 9.4 days per employee per year -- the highest level in over 15 years -- with financial stress recognised as a contributing factor to both presenteeism and mental health-related absence.4 Senior leadership engagement with wellbeing has increased: 74% of HR professionals report that senior leaders have employee wellbeing on their agenda, up from 61% five years prior, and 75% of line managers buy into its importance.4

1.2 Financial Wellbeing as a Strategic Capability

The CIPD defines financial wellbeing as the ability to "make the most of money day-to-day, deal with the unexpected, and plan for the future."5 This tripartite definition is significant: while most employer programmes address the first two dimensions -- budgeting tools, debt advice, emergency savings -- the third dimension, future planning, remains materially underserved. Estate planning -- wills, beneficiary nominations, lasting powers of attorney -- falls squarely within this definition but receives negligible employer attention.

The data supports the business case for structured provision. In organisations where a financial wellbeing policy is in place, 76% of employees report feeling in control of their finances, and 61% say their pay is sufficient to help them save for retirement.6 Despite this, only 20% of UK organisations ask employees about their financial wellbeing at least once a year.7 This measurement gap means most employers lack the diagnostic data to identify where estate planning education would deliver the greatest impact. Employer engagement with financial wellbeing assessment remains the exception rather than the norm, and 59% of staff believe it is important that their present employer has a financial wellbeing policy, rising to 65% for a future employer -- signalling a recruitment and retention dimension.5

1.3 The Wellbeing Strategy Landscape

The broader organisational context is favourable. The CIPD Health and Wellbeing at Work Survey 2025 reports that 57% of UK organisations now have a stand-alone wellbeing strategy, up 13 percentage points since 2020.4 Crucially, 67% of organisations provide bereavement support and 75% support employees with caring responsibilities for young children.4 These existing provisions represent natural gateways to estate planning awareness: bereavement support intersects directly with probate, will validity, and beneficiary nomination processes, while caring responsibilities raise questions about guardianship provisions and lasting powers of attorney.

The HM Treasury Financial Inclusion Strategy, published in November 2025, further reinforces the employer role. The Strategy establishes a National Coalition of Employers to drive awareness and adoption of workplace savings schemes, supported by FCA regulatory clarity for employers offering such programmes.8 Auto-save models supported under the Strategy achieve 40-69% participation rates, with employees saving between GBP 40 and GBP 170 monthly on average.8 While the Strategy does not mandate employer provision, the direction of travel -- encouraging employers as conduits for financial wellbeing -- aligns with integrating estate planning education into existing frameworks.

2. April 2027: Why Pension Inheritance Tax Changes Demand Employer Engagement

2.1 The Scope of the Change

From 6 April 2027, most unused pension funds and death benefits will be included within the value of a person's estate for Inheritance Tax purposes.9 This represents a fundamental shift in the relationship between workplace pension accumulation and estate planning. Prior to this change, pension funds held in drawdown or uncrystallised defined contribution arrangements were generally outside the scope of IHT, making pensions one of the most tax-efficient vehicles for intergenerational wealth transfer. The provisions are contained in Finance (No. 2) Bill 2025-26, which as of February 2026 is progressing through Parliament following Committee of the Whole House in January 2026 and Public Bill Committee proceedings; Royal Assent is anticipated ahead of the April 2027 effective date.9

The government estimates that of approximately 213,000 estates with inheritable pension wealth in 2027-28, 10,500 will newly face IHT liability and 38,500 will pay increased IHT as a result of the changes.10 The implications for workplace pension strategy are direct: employees who have been encouraged -- through auto-enrolment and additional voluntary contribution campaigns -- to maximise pension savings will find that this accumulation now has IHT consequences their previous planning may not have anticipated.

2.2 Exclusions and Carve-Outs Relevant to Employer Benefits

Not all employer-provided death benefits fall within the new IHT scope. Death-in-service benefits payable from registered pension schemes are explicitly excluded from the April 2027 changes.11 Dependant's scheme pensions from defined benefit and collective money purchase arrangements are also excluded.9 Group life insurance premiums remain non-taxable benefits in kind under ITEPA 2003 s 307, and lump sums paid through discretionary trusts continue to fall outside the deceased's estate for IHT purposes.12 Excepted group life policies -- those arranged outside registered pension schemes -- also remain outside IHT scope, though HMRC has been asked to clarify the treatment of certain employer-arranged group life structures.11

This distinction between death-in-service benefits (excluded) and unused pension funds (included) is critical for total rewards communication. Employers providing group life cover alongside defined contribution workplace pensions must communicate this differential treatment clearly: the death-in-service lump sum remains IHT-free, but the pension pot accumulated through the same employer's scheme may now attract IHT. Existing spousal and civil partner exemptions are maintained, as are charity exemptions, which means the IHT exposure applies primarily to benefits directed to adult children, extended family, or other non-exempt beneficiaries.

2.3 Liability, Reporting, and the Withholding Mechanism

The government's consultation response, published in October 2025, confirmed that personal representatives -- not pension scheme administrators -- will be liable for reporting and paying IHT on unused pension funds and death benefits.13 This reversal from the original consultation proposal (which placed liability on scheme administrators) followed significant industry feedback and has practical implications for employee communication: beneficiaries and executors, not the employer or pension provider, bear the administrative and financial burden.

Personal representatives may direct scheme administrators to withhold up to 50% of benefits for up to 15 months to cover the IHT liability.13 Total rewards directors should recognise that employees who have nominated pension death benefits to non-exempt beneficiaries (persons other than spouses, civil partners, or charities) may expose those beneficiaries to both IHT liability and potential liquidity constraints during the withholding period. This creates a communication responsibility: employees need to understand not merely the existence of IHT exposure but the practical mechanisms through which it will be administered.

2.4 The Auto-Enrolment Intersection

The interaction between auto-enrolment and the April 2027 changes warrants particular attention. Auto-enrolment requires minimum combined contributions of 8% of qualifying earnings (3% employer, 5% employee) on earnings between GBP 6,240 and GBP 50,270 for 2025-26.14 Over a working lifetime, these contributions -- together with investment growth and any additional voluntary contributions -- can generate material pension wealth. For the first time, that accumulated wealth carries IHT exposure if unused at death.

Employers who actively encourage pension saving through matching contributions, salary sacrifice arrangements, or workplace financial education now bear a corresponding responsibility to ensure employees understand the changed tax consequences. Failing to do so risks a scenario where the benefits provided and promoted by the employer are undermined by employees' lack of awareness of the estate planning implications.

3. Estate Planning Within Total Rewards: Programme Components

3.1 Will-Writing Services

Employer-funded will-writing services represent the most direct estate planning intervention available within a total rewards framework. Wills coordinate with workplace death benefits by ensuring that pension death benefit nominations, group life insurance designations, and personal estate provisions operate cohesively. Without a valid will, intestacy rules apply -- and as discussed in Section 5, these rules may produce outcomes that do not reflect employees' wishes, particularly for those in non-traditional family structures.

The tax treatment of employer-funded will-writing services is straightforward: where the employer meets the cost, the benefit is a taxable benefit in kind reportable on P11D.15 The trivial benefits exemption under ITEPA 2003 s 323A -- which exempts benefits costing no more than GBP 50, provided they are not contractual, not salary sacrifice, and not cash or cash vouchers -- may cover basic will-writing services at the lower end of the cost spectrum, but most comprehensive services exceed this threshold.15 Employers may choose to negotiate group rates with will-writing providers, reducing per-employee costs while acknowledging the benefit-in-kind reporting obligation.

3.2 Pension Death Benefit Nomination Reviews

Expression of wish forms for pension death benefits are administered through HR and payroll functions but are rarely subject to systematic review. Outdated nominations -- reflecting former spouses, deceased relatives, or pre-civil-partnership designations -- create distress for bereaved families and potential complications for scheme trustees exercising their discretion.

Employer-initiated nomination review campaigns cost nothing to implement but can materially improve outcomes. Best practice involves prompting employees to review nominations at defined trigger points: marriage, divorce, birth of a child, bereavement, and -- following April 2027 -- any material change in pension accumulation that might affect IHT exposure. The operational process sits within existing HR administrative workflows and requires no specialist estate planning expertise. A structured annual prompt, coordinated with benefits enrolment windows, establishes nomination review as a routine element of benefits administration rather than an exceptional request.

3.3 Group Life Insurance Beneficiary Designation

Group life insurance beneficiary designations operate on a similar basis to pension nominations but are often managed through separate administrative systems. Where death-in-service benefits are paid into a discretionary trust (the standard arrangement for IHT efficiency), the trustees retain discretion over distribution, but the employee's expression of wish form guides that discretion.12 Regular review of these designations, coordinated with pension nomination reviews, ensures consistency across the employer's death benefit provision. The administrative cost of consolidating nomination review processes across pension and group life schemes is minimal; the risk reduction is material.

3.4 Financial Education Sessions

Financial education sessions that address the interaction between workplace benefits and personal estate planning represent a scalable, low-cost intervention. Content might include: the importance of wills and lasting powers of attorney; how pension death benefits and group life insurance interact with personal estate planning; the April 2027 pension IHT changes and their practical implications; and the difference between expression of wish nominations and testamentary bequests. The critical constraint is the FCA advice-guidance boundary, addressed in Section 4.

Delivery models range from in-house workshops led by HR teams (covering general awareness only) to outsourced sessions delivered by financial education providers. The tax treatment differs by model: general awareness sessions provided to all employees are less likely to attract benefit-in-kind treatment than individualised guidance sessions, though the boundary depends on the specificity of content delivered.

3.5 Lasting Power of Attorney Awareness

Lasting powers of attorney -- for both health and welfare and property and financial affairs -- complement estate planning by addressing incapacity during lifetime. For employers providing group income protection, there is a logical connection: employees receiving long-term disability benefits may simultaneously require financial affairs management through an LPA. Awareness campaigns positioning LPA registration alongside pension and death benefit reviews strengthen the coherence of the total rewards estate planning offering.

4. Navigating the Tax and Regulatory Boundaries

4.1 The Welfare Counselling Exemption: ITEPA 2003 s 210

The welfare counselling exemption under the Income Tax (Earnings and Pensions) Act 2003 s 210, as implemented by SI 2000/2080, is frequently misunderstood by HR teams when designing employee assistance programme scope. The exemption covers counselling on stress, workplace problems, debt issues, substance dependency, career concerns, bereavement, discrimination, health conditions, abuse, harassment, bullying, and relationship difficulties.16 From 6 April 2020, following SI 2020/291, medical treatments delivered as counselling (such as cognitive behavioural therapy and interpersonal therapy) also became exempt.16

Critically, the exemption specifically excludes "advice on finance (other than advice on debt problems), or advice on tax, or advice on leisure or recreation, or legal advice."16 Estate planning advice -- encompassing will drafting, trust structures, and tax mitigation -- falls outside the exemption on multiple grounds: it constitutes financial advice, potentially tax advice, and potentially legal advice. Any estate planning services delivered through an employee assistance programme therefore constitute a taxable benefit in kind, and mixed-service programmes require careful separation to preserve the exemption for qualifying components. The exemption applies only where substantially all programme components satisfy the criteria; a single non-qualifying element risks tainting the entire provision.

4.2 Benefit-in-Kind Treatment and Mandatory Payrolling

Employer-funded estate planning services that fall outside the welfare counselling exemption must be treated as benefits in kind. Currently, these are reportable on P11D; however, mandatory payrolling of benefits in kind -- originally announced for April 2026 and subsequently deferred to April 2027 -- will change the reporting mechanism.17 From April 2027, employers providing will-writing services, financial education sessions with individualised content, or other estate planning support as employment benefits will be required to payroll these benefits, calculating and deducting income tax through PAYE in real time rather than reporting annually through P11D.

This coincidence of timing -- the mandatory payrolling of benefits and the pension IHT changes both effective from April 2027 -- creates a compliance inflection point. Total rewards teams designing estate planning programme components should factor the payrolling requirements into their cost modelling and delivery design from the outset.

4.3 The Trivial Benefits Exemption: Practical Boundaries

The trivial benefits exemption under ITEPA 2003 s 323A provides a narrow window for tax-efficient provision of low-cost estate planning materials.15 Financial education booklets, guides, or digital resources costing less than GBP 50 per employee may qualify, provided they are non-contractual, not salary sacrifice, and not cash or cash vouchers. However, HMRC treats reimbursement of personal expenses as equivalent to cash, so an employer cannot reimburse an employee's will-writing costs under this exemption. Directors of close companies face an additional annual cap of GBP 300 across all trivial benefits received.

4.4 The Financial Conduct Authority Advice-Guidance Boundary

The distinction between financial guidance and regulated financial advice is the most significant regulatory boundary for employer-delivered estate planning education. Employers can provide general financial education and guidance -- including awareness of the need for wills, the importance of nomination reviews, and the existence of lasting powers of attorney -- without crossing into regulated advice territory.18

Individualised recommendations -- specific trust structures, tax mitigation strategies tailored to an employee's circumstances, or recommendations about pension drawdown versus annuity in light of IHT exposure -- constitute regulated financial advice requiring FCA authorisation.18 Employers must ensure that financial education sessions are designed and delivered within the guidance boundary, with clear signposting to regulated advisors for personalised advice.

4.5 The Targeted Support Regime: PS25/22

The FCA's targeted support regime, established under Policy Statement PS25/22 and effective from 6 April 2026, introduces a significant development. The regime allows firms to make limited recommendations to groups of consumers with common characteristics without full individualised suitability assessments.19 The FCA estimates that 18 million or more people could receive additional help with investments and pensions over 10 years as a result.19

For total rewards strategy, the targeted support regime means that pension providers serving workplace schemes may, from April 2026, offer group-level pension guidance that complements employer-led financial wellbeing programmes. This might include targeted communications to employee cohorts approaching retirement about the IHT implications of their pension accumulation -- a form of support that sits between generic education and full regulated advice. Benefits consultants designing financial wellbeing programmes should coordinate with pension providers to leverage this new regime as part of an integrated estate planning awareness strategy.

5. Diversity, Equity, and Inclusion in Estate Planning Provision

Financial wellbeing outcomes vary significantly by income level. The CIPD Good Work Index 2025 reports that only 35% of those paid less than GBP 20,000 per annum can keep up with bills without difficulty, compared with 54% across all income levels.1 Lower-paid employees are disproportionately reliant on employer-provided death-in-service benefits as their sole life cover and are less likely to have made wills or established lasting powers of attorney. Estate planning education within financial wellbeing programmes addresses this disparity directly, ensuring that the protective value of employer-provided death benefits is not undermined by the absence of complementary personal planning.

The REBA Financial Wellbeing Research 2025 identifies that employers expect inflation (76%), childcare costs (73%), and high mortgage interest rates (58%) will continue as risks to staff financial wellbeing.3 These pressures fall disproportionately on lower-income employees, reducing the likelihood that they will independently seek estate planning services. Employer-facilitated provision, even at the basic level of awareness and signposting, reaches employees who would otherwise remain unserved.

5.2 Family Structure and Intestacy Rules

The Administration of Estates Act 1925, as amended, governs intestate succession in England and Wales. Critically, the intestacy rules make no provision for unmarried cohabiting partners, irrespective of the duration of the relationship or the presence of shared children.20 Same-sex partners who have not entered into a civil partnership or marriage, blended families with stepchildren, and other non-traditional structures face estate planning requirements where default nomination forms and intestacy provisions may produce outcomes fundamentally at odds with the employee's intentions.

An inclusive total rewards approach requires nomination processes that accommodate diverse family structures and estate planning education that explicitly addresses the limitations of intestacy rules. Standard expression of wish forms should be reviewed for inclusivity: do they accommodate multiple beneficiaries, non-traditional relationships, and complex family arrangements? Do accompanying guidance materials explain the consequences of not making a will for employees in these circumstances? The DEI dimension extends beyond programme content to programme access: estate planning education sessions should be available in formats and at times that reach shift workers, part-time employees, and those in remote or distributed working arrangements.

Estate planning needs vary across the employee lifecycle. Younger employees with dependants face guardianship and life insurance adequacy questions. Mid-career employees navigating divorce or second relationships require nomination updates and will revisions. Employees approaching retirement face the most acute interaction with the April 2027 changes: their accumulated pension wealth will, for the first time, carry IHT exposure that may require reconfiguration of their estate plans. Effective programme design segments communication and education by career stage, ensuring relevance across the workforce while avoiding a one-size-fits-all approach that risks disengagement.

Conclusion

The inclusion of unused pension funds within IHT estates from April 2027 marks a structural shift that elevates estate planning from peripheral consideration to strategic imperative within total rewards. The evidence is clear: financial stress affects nearly a third of employees' work performance, yet employer engagement with the future-planning dimension of financial wellbeing remains underdeveloped. Estate planning -- will-writing services, death benefit nomination reviews, lasting power of attorney awareness, and financial education addressing the pension-estate interaction -- represents a logical extension of existing employer provision, not a new standalone benefit.

The regulatory and tax framework, while requiring careful navigation, does not prevent employer engagement. The welfare counselling exemption boundary must be respected, benefit-in-kind implications factored into programme costing, and the FCA advice-guidance distinction maintained in all employee communications. The targeted support regime from April 2026 creates additional opportunities for pension providers to complement employer-led education with group-level guidance.

Total rewards directors who integrate estate planning into financial wellbeing frameworks address the REBA-identified barrier of employees not knowing where to start, strengthen the coherence of death benefit and pension provision, and align with DEI objectives by ensuring that employer benefits serve employees across all income levels, family structures, and career stages. The cost is modest -- nomination review processes are cost-neutral, financial education sessions are scalable, and will-writing partnerships can be negotiated at group rates. The strategic alignment with existing wellbeing strategies, pension provision, and bereavement support is compelling. As the April 2027 effective date approaches, the window for programme design and implementation is narrowing: total rewards teams that initiate programme development at this stage position their organisations to support employees through a material change in the tax treatment of workplace pension wealth.


CPD Declaration

Estimated Reading Time: 18 minutes Technical Level: Advanced Practice Areas: Total Rewards Strategy, Financial Wellbeing, Employee Benefits Compliance, Pension Administration

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Evaluate the strategic case for integrating estate planning education into employer financial wellbeing programmes using CIPD and REBA workforce data
  2. Distinguish between employer-provided death benefits excluded from the April 2027 pension IHT changes and unused pension funds that fall within scope
  3. Apply the welfare counselling exemption boundary (ITEPA 2003 s 210) and the trivial benefits exemption (s 323A) when designing estate planning programme components
  4. Analyse how intestacy rules and diverse family structures affect the inclusivity of employer death benefit nomination processes

Competency Mapping

  • CIPD Advanced Diploma: Reward Management -- designing and evaluating total rewards strategies
  • CIPD Advanced Diploma: People Management -- employee wellbeing and engagement
  • REBA Accreditation: Financial Wellbeing Strategy -- programme design and compliance

Reflective Questions

  1. How would the April 2027 pension IHT changes affect communication strategies for workplace pension schemes within a total rewards framework?
  2. What steps could be taken to audit existing death benefit nomination processes for inclusivity across diverse family structures and relationship types?
  3. How might the FCA targeted support regime (PS25/22) be leveraged alongside employer financial education to provide more comprehensive pension and estate planning guidance to employees?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-25. 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. CIPD Good Work Index 2025 (June 2025). https://www.cipd.org/globalassets/media/knowledge/knowledge-hub/reports/2025-pdfs/8868-good-work-index-2025-report-web1.pdf 2 3

  2. REBA Financial Wellbeing Research 2025 (2025). https://reba.global/resource-report/financial-wellbeing-research-2025.html

  3. REBA Financial Wellbeing in 2025: A Snapshot of Current Workforce Trends (2025). https://reba.global/resource/financial-wellbeing-in-2025.html 2

  4. CIPD Health and Wellbeing at Work Survey 2025 (September 2025). https://www.cipd.org/globalassets/media/knowledge/knowledge-hub/reports/2025-pdfs/8920-Health-and-wellbeing-report-2025-/ 2 3 4

  5. CIPD -- Why Should Employers Take Action on Employee Financial Wellbeing? (2025). https://www.cipd.org/uk/views-and-insights/thought-leadership/insight/action-employee-financial-wellbeing/ 2

  6. CIPD -- Why Should Employers Take Action on Employee Financial Wellbeing? (2025). https://www.cipd.org/uk/views-and-insights/thought-leadership/insight/action-employee-financial-wellbeing/

  7. CIPD Employee Financial Wellbeing Practical Guide (February 2023). https://www.cipd.org/globalassets/media/knowledge/employee-financial-wellbeing_tcm18-113886.pdf

  8. HM Treasury -- Financial Inclusion Strategy (November 2025). https://www.gov.uk/government/publications/financial-inclusion-strategy/financial-inclusion-strategy 2

  9. GOV.UK -- Inheritance Tax: Unused Pension Funds and Death Benefits (Policy Paper, October 2024). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits 2 3

  10. GOV.UK -- Inheritance Tax: Unused Pension Funds and Death Benefits (Policy Paper, October 2024). https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits

  11. KPMG -- Inheritance Tax Changes: Is Your Employee Group Life Plan Affected? (2025). https://kpmg.com/uk/en/insights/tax/tmd-inheritance-tax-changes-is-your-employee-group-life-plan-affected.html 2

  12. HMRC Employment Income Manual EIM15045 -- Employer-Financed Retirement Benefits Schemes: Relevant Life Policies. https://www.gov.uk/hmrc-internal-manuals/employment-income-manual/eim15045; HMRC Inheritance Tax Manual IHTM17091 -- Pensions: Excepted Group Life Policies. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm17091; Drewberry -- How Is Death in Service Insurance Taxed? https://www.drewberryinsurance.co.uk/employee-benefits/faqs/how-is-death-in-service-taxed 2

  13. GOV.UK -- IHT on Pensions: Liability, Reporting and Payment -- Summary of Responses (October 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 2

  14. The Pensions Regulator -- Earnings Thresholds 2025-26. https://www.thepensionsregulator.gov.uk/en/employers/new-employers/im-an-employer-who-has-to-provide-a-pension/declare-your-compliance/ongoing-duties-for-employers/earnings-thresholds

  15. ITEPA 2003, s 323A -- Trivial Benefits. https://www.legislation.gov.uk/ukpga/2003/1/section/323A; GOV.UK -- Tax Exemption for Trivial Benefits in Kind: Draft Guidance. https://www.gov.uk/government/publications/tax-exemption-for-trivial-benefits-in-kind-draft-guidance/tax-exemption-for-trivial-benefits-in-kind-draft-guidance 2 3

  16. ITEPA 2003, s 210. https://www.legislation.gov.uk/ukpga/2003/1/section/210; GOV.UK -- Income Tax Treatment of Welfare Counselling. https://www.gov.uk/government/publications/income-tax-treatment-of-welfare-counselling/income-tax-treatment-of-welfare-counselling; SI 2000/2080 as amended by SI 2020/291. https://www.legislation.gov.uk/uksi/2020/291/made 2 3

  17. GOV.UK -- Technical Note: Mandating the Reporting of Benefits in Kind and Expenses Through Payroll Software -- An Update (April 2025). https://www.gov.uk/government/publications/reporting-and-paying-income-tax-and-class-1a-national-insurance-contributions-on-benefits-in-kind-in-real-time-an-update/technical-note-mandating-the-reporting-of-benefits-in-kind-and-expenses-through-payroll-software-an-update

  18. FCA -- Advice Guidance Boundary Review. https://www.fca.org.uk/firms/advice-guidance-boundary-review 2

  19. FCA PS25/22 -- Supporting Consumers' Pensions and Investment Decisions: Rules for Targeted Support (December 2025). https://www.fca.org.uk/publications/policy-statements/ps25-22-consumer-pensions-investment-decisions-rules-targeted-support 2

  20. Administration of Estates Act 1925 (as amended). https://www.legislation.gov.uk/ukpga/Geo5/15-16/23

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