The increase in the Normal Minimum Pension Age to 57 in April 2028 could have important implications for some retirement income strategies. Mark Plewes, Head of Pensions Technical at WBR Group, explains why clients using phased drawdown or UFPLS may need to review their plans well before the new rules take effect.
For those working within pensions and advice, the increase in the Normal Minimum Pension Age (NMPA) from 55 to 57 on 6 April 2028 has been anticipated for well over a decade. Legislated through the Finance Act 2022, it forms part of the government’s wider policy of linking pension access more closely to increases in the State Pension Age.
The same awareness cannot be assumed among pension savers, many of whom remain unaware of changes that could significantly affect their retirement plans. For those who are aware, the change adds an additional complication requiring careful consideration and planning.
The general rule is straightforward. From 6 April 2028, the minimum age at which most individuals can access pension benefits from most occupational and personal pension schemes without triggering an unauthorised payment tax charge will rise from 55 to 57.
Whilst this might appear simple, greater flexibility over when and how people access pensions makes it anything but.
The change could significantly affect not only clients yet to access their pensions, but also those already taking benefits who expect to continue drawing funds between ages 55 and 57 on or after 6 April 2028.
One key area of focus has been the anticipated finalisation and publication of transitional regulations for people born between 6 April 1971 and 5 April 1973.
They will be aged 55 or 56 on 6 April 2028 and, under the previous rules, could have accessed pension benefits from age 55 by 5 April 2028, the day before the change takes effect.
The position is yet to be finalised, but HMRC issued their draft regulations on 6 August 2026 with a consultation that ran until the last week of September 2026.
As drafted, the regulations protect specified payments made on or after 6 April 2028 where entitlement arose before that date and the member is not yet 57.
The regulations aim to preserve authorised payment status for income paid after that date from funds already in drawdown, or from an annuity in place before it, where the member has not reached age 57.
The regulations also allow certain lump sums, such as PCLS, to be paid on or after 6 April 2028 if entitlement arose before that date and the member had an actual right to the benefit, with no further conditions or actions required from them.
This covers, for example, members who designated funds into drawdown and requested and became entitled to PCLS before 6 April 2028, but whose payment is made on or after that date because of administration or processing times outside their control.
These transitional regulations do not provide such protections for UFPLS as the member only becomes entitled to the uncrystallised funds pension lump sum immediately before it is paid.
It is important to recognise that these provisions are not a blanket solution and do not allow unrestricted access between ages 55 and 57 for individuals born between these dates.
The legislation effectively prevents new crystallisations into UFPLS or new money being placed into drawdown with an associated PCLS on or after 6 April 2028, even where part of the individual’s pension has previously been crystallised within that scheme or elsewhere.
For advisers, paraplanners and administrators supporting clients taking benefits gradually through phased drawdown or a series of UFPLS payments, this creates a significant planning challenge. Phased retirement strategies become particularly vulnerable for individuals in this age group following the changes.
For example, a client aged 55 in 2027 may plan to crystallise benefits gradually over several years, taking partial PCLS and drawdown payments or UFPLS as income is required. They may expect access to continue unaffected, but without a protected pension age, further crystallisations on or after 6 April 2028 are likely to be blocked until age 57.
A retirement income strategy built around regular annual crystallisations, or UFPLS payments could therefore fail at exactly the point the client expects the pension to continue funding expenditure.
Retirement plans spanning the 2028 transition therefore need early review. Clients may encounter a genuine cashflow gap where their retirement income plan assumes continuing pension access between ages 55 and 57 that will no longer be available.
Individuals relying on phased crystallisation, staggered UFPLS withdrawals or ad hoc access to uncrystallised funds may need an alternative strategy, such as bringing forward benefit events, holding larger cash reserves within drawdown, or reconsidering the timing and structure of retirement income.
With the NMPA change less than two years away, the critical question is whether retirement income plans can continue when individuals may temporarily lose access to pension funds between ages 55 and 57. Early planning and careful advice will be essential to avoid unwelcome surprises.
Main image: gap, missing, brett-jordan-ulqQgJRGVNc-unsplash
