The Main Changes in the 2025-26 CII R04 Study Text
In this article, we look at the main syllabus changes in the CII’s 2025/26 R04 study text. Most of these stem from the tidying up of the rules around the new Lump Sum Allowance (LSA) and Lump Sum Death Benefit Allowance (LSDBA) from April 2024. There were also some deadlines that passed and one or two new ones that will affect pension planning.
This article is correct as at 31 August 2025 and is relevant to the 2025/26 examinable tax year.
Transitional Protections
The deadline to apply for Individual or Fixed Protection (FP) 2016 passed on 5 April 2025. Those people who had secured a FP certificate by 15 March 2023 can resume benefit accrual whilst retaining their higher Lump Sum Allowance (LSA) and Lump Sum Death Benefit Allowance (LSDBA) limits.
ROPS (Recognised Overseas Pension Scheme)
A transfer in from a ROPS to a UK scheme entitled the member to apply for an enhanced LSA/LSDBA limit as the overseas scheme would not have had the same tax breaks as a UK scheme. The deadline to apply for any enhancement expired on 5 April 2025.
Class 3 NI
Class 3 NI can be paid by eligible contributors who want to buy additional NI credits for missed tax years so that they can get to the 35 needed for a full State Pension. The DWP had allowed people to buy-back missed years as far back as April 2006, but this extended period to buy credits ended on 5 April 2025. The standard Class 3 rules now apply, enabling people to gain credits from only the last 6 tax years.
Sustainable Environmental, Social, Governance (ESG) Pension Investment Funds
This investment interest has increased with environmental, social, governance (ESG), ethical or religious considerations now accounting for over 50% of client fund decisions (according to PFS surveys).
‘Greenwashing’ – making misleading or false statements about the environmental impacts of funds or services to attract investors – has been addressed by new regulations from the FCA, effective from 31 May 2024. The new requirements include ensuring any sustainability claims must be fair, clear and not misleading, product labels to help investors understand what their money is being used for and making sure product descriptions accurately describe their impact on sustainability.
Statutory Money Purchase Illustrations (SMPI)
Regulations require providers to issue an illustration to all members of money purchase pension contracts at least once a year. There are exceptions, such as for RACs or SSASs, but the idea is to enable the member to get a ‘real time’ projection of their benefits at retirement. For illustrations after 5 April 2024, all providers must use the same rates of growth, inflation and annuity so that all members get consistent figures. This will reduce confusion whilst also enabling a better comparison of benefits for everyone from October 2026 when the Government’s Pension Dashboard is planned to go live.
DB Scheme Deficits
DB schemes in deficit must have a recovery plan, agreed between the scheme Trustees and the employer and submitted to TPR. Some changes have been made that require fuller consideration of any available cash of the employer – the reliability of future cashflows and the alternative options for the cash by the employer besides deficit reduction.
Collective Defined Contribution Schemes (CDCs)
Introduced by the Pension Schemes Act 2021, this new form of collective pension funding offers an alternative to DB and DC schemes. The scheme assets can be pooled between members, helping to produce less expensive and more predictable returns than individual DC pots. This approach should also avoid the long-term risks and costs of a DB scheme to the employer. You can expect to hear more about these in the future.
Transitional Tax-Free Amount Certificates (TTFACs)
A TTFAC may no longer be required for members who reached age 75 before 6 April 2024, if they had a benefit crystallisation event (BCE) at age 75 that did not generate any tax-free lump sum, and they did not take any further tax-free amounts between age 75 and 6 April 2024. This is due to amended regulations introduced in November 2024 (and backdated to 6 April 2024), which allow such BCEs to be ignored under the standard transitional basis.
Inheritance Tax on DC Pension Funds
The October 2024 budget announced that IHT would be assessed on DC pension funds for deaths on or after 6 April 2027. HMRC is currently forming the rules, documentation and procedures to enable pension providers and legal personal representatives make this happen. Pension funds left to spouse’s will still be IHT free but there may be an impact on Residence Nil Rate band entitlements for estates – to then include pension funds – over £2 million. The detailed rules are being developed so advisers should keep an eye on developments.
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