Pensions industry bodies have called on HMRC to provide greater clarity and extend transitional protections ahead of the increase in the normal minimum pension age (NMPA) from 55 to 57, warning that some payments made after 6 April 2028 could otherwise be treated as unauthorised.

The NMPA is due to increase from 55 to 57 from 6 April 2028.

HMRC’s draft regulations are intended to protect specified payments where members aged 55 or 56 had already become entitled to benefits before the change takes effect.

The Investing and Saving Alliance (TISA) said the draft regulations broadly provided schemes with the detail needed to prepare, but warned there was still uncertainty for people already receiving pension income through drip-feed arrangements, taking tax-free cash in instalments or holding a protected pension age of 55.

TISA head of policy: products and long-term savings, Renny Biggins, said: “Moving the minimum pension age from 55 to 57 should not significantly change most people’s retirement plans, but the transition needs to work properly for those already accessing their pension or who have made plans based on the current rules.

“There are still situations where the draft regulations leave uncertainty.”

He added that HMRC should clarify that pension or annuity payments that started before April 2028 could continue while members remained aged 55 or 56, and provide greater clarity on protected pension ages following transfers.

TISA also warned the change could encourage some people aged 55 or 56 to access tax-free cash earlier than planned to avoid losing flexibility for up to two years.

It called for a government public-awareness campaign ahead of implementation, while also recommending that the Financial Conduct Authority consider how the change affects pension wake-up packs and that the age 75 pension threshold be increased to 77 to maintain the existing 20-year gap with the NMPA.

The SPP raised similar concerns, arguing that HMRC should formally confirm that pensions already in payment before 6 April 2028 can continue uninterrupted.

It said the position should ideally be confirmed permanently through the Pensions Tax Manual, given uncertainty over whether the NMPA test applies only when the first pension payment is made or to every subsequent payment.

The Society of Pension Professionals (SPP) also called for transitional protection to be extended to other lump sums for which entitlement arose before 6 April 2028 but payment was subsequently delayed.

It warned that members could otherwise face “significant and unexpected” unauthorised payment charges because of administrative delays outside their control.

In particular, the SPP highlighted UFPLS payments, where entitlement under current legislation arises immediately before payment.

It noted that someone could take the steps required to request an UFPLS before the deadline but, if payment was delayed until after 5 April 2028, technically become entitled only after the NMPA had risen to 57.

The Association of Consulting Actuaries (ACA) also called for clearer treatment of UFPLS and annuity purchases, warning that differences between these benefits and scheme pension or drawdown arrangements would be difficult for members to understand.

It stressed that administrative delays could mean some payments requested before the change were not completed until after the deadline and urged HMRC to consider extending the transitional provisions accordingly.

The ACA also highlighted people using UFPLS payments as a form of retirement income.

It noted that a member without a protected pension age who had begun taking UFPLS payments before April 2028 would currently be unable to continue doing so after the change until reaching 57, potentially interrupting an established income stream.

The association argued there was a case for protecting further UFPLS payments where at least one payment had already been taken from the same uncrystallised fund before 6 April 2028.

Both the SPP and ACA also called for transitional protection around small lump sums and authorised member surplus payments.

The SPP argued that members who had already received an authorised member surplus payment before April 2028 should be able to continue receiving further payments until age 57, while the ACA called for payments for which entitlement arose before the NMPA change to remain payable from age 55.

The SPP urged HMRC to finalise the regulations quickly, warning that delays could increase uncertainty and lead members to change retirement decisions based on incomplete information.

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