Administration: Role and responsibilities of the Scheme Administrator

Under section 270 of the FA04, the scheme administrator is responsible for the tax affairs of the scheme and for ensuring that it complies with its tax obligations.

To be appointed as a scheme administrator, a person or persons must be resident in an EU member state or in Norway, Liechtenstein or Iceland.  In many cases, the administrator will be the trustees.


The scheme administrator’s duties include:

  • registering the pension scheme with HMRC;
  • operating tax relief on contributions under the relief at source system;
  • reporting events relating to the scheme and the scheme administrator to HMRC;
  • making returns of information to HMRC;
  • providing information to scheme members, and others, regarding the lifetime allowance, benefits and transfers.

However, they can appoint a practitioner to act on their behalf in relation to some of the above.

Liability to tax

The scheme administrator is liable for payment of certain tax charges under Part 4 of the FA04 in connection with the scheme.  If more than one person is appointed as scheme administrator, each is jointly and severally liable for any tax charges or penalties.


It is only possible to register as a scheme administrator using HMRC’s online facility on their website.