Resources & Insights

HMRC Updates QROPS List 2026: What It Means for Expat Transfers

By QROP Direct Editorial Team · Reviewed by an independent regulated pension specialist · Reviewed 2026-06-10

HMRC Updates QROPS List 2026: What It Means for Expat Transfers

The HMRC recognised QROPS list is not a fixed document. It is a living register that HMRC updates on a rolling basis — typically fortnightly — reflecting which Qualifying Recognised Overseas Pension Schemes meet the standards required to accept UK pension transfers. Schemes can be added to the list, removed from it, or placed under notice, depending on whether they satisfy HMRC's regulatory requirements.

For UK expats considering a pension transfer to a QROPS, staying up to date with list changes is essential. Transferring to a scheme that was recognised at the time you decided to transfer but has since been removed creates significant risk — and demonstrates why using a regulated adviser who monitors scheme status is so important.

This article summarises what has changed on the QROPS list in 2026, what the trends mean for expats planning a transfer, and how to protect yourself from the consequences of selecting a scheme that falls foul of HMRC's standards.

Disclaimer: This article is for general information only. The QROPS list changes frequently. Always verify current scheme status directly on GOV.UK before proceeding with a transfer, and seek regulated financial advice.

Key Takeaways

• HMRC updates the QROPS list approximately fortnightly; checking GOV.UK immediately before any transfer is essential
• Malta and Gibraltar remain the dominant QROPS jurisdictions with the greatest number of recognised schemes
• Regulatory compliance requirements have tightened in 2026, with enhanced reporting and governance standards
• Several non-EU jurisdictions have seen their QROPS offerings expand in 2026
• The Overseas Transfer Charge (25%) applies to transfers to QROPS schemes outside the EEA, and now applies to EEA transfers too following the October 2024 rule change
• Due diligence on scheme operators and administrators is as important as scheme recognition status

How the QROPS List Works

HMRC publishes a list of recognised overseas pension schemes on GOV.UK. Inclusion on this list means the scheme has confirmed to HMRC that it meets the conditions laid down in the Finance Act 2004 for QROPS recognition, including:

• Being regulated under the law of an overseas territory
• Having rules that prevent more than 70% of the pension savings being used to provide a pension before death
• Requiring member benefits to be taxable under the laws of the relevant territory
• Complying with HMRC's reporting obligations, including the ten-year reporting requirement

Recognition is self-certified by the scheme and monitored by HMRC. When a scheme no longer meets the requirements — whether because the scheme rules changed, the regulatory environment shifted, or reporting obligations were not met — HMRC removes it from the list.

Crucially, inclusion on the list does not constitute HMRC endorsement of the scheme, its management, or its investment choices. A recognised QROPS may still be poorly managed, carry high charges, or invest in inappropriate assets. Regulatory due diligence and adviser review remain essential.

2026 List Changes and Trends

Malta: Dominant and Growing

Malta continues to host the largest number of QROPS schemes on the HMRC recognised list in 2026. Malta's QROPS framework is regulated by the Malta Financial Services Authority (MFSA), which has maintained close alignment with HMRC's evolving requirements. New scheme operators have obtained MFSA authorisation and HMRC recognition in the first half of 2026, expanding the number of Malta QROPS options available to UK expats.

Malta's dominance reflects several factors: its EU membership (providing access to financial markets and passporting arrangements), its English-language legal and regulatory system, its double taxation agreements with the UK, and the maturity of its pensions industry. For most UK expats considering a QROPS, Malta schemes offer the broadest range of investment options and the most competitive fee structures. (Source: HMRC: Recognised Overseas Pension Schemes, January-June 2026)

Gibraltar: Strong and Stable

Gibraltar remains the second-most prominent QROPS jurisdiction. Gibraltar's regulatory framework — overseen by the Gibraltar Financial Services Commission (GFSC) — has maintained its recognition standards, and no significant Gibraltar QROPS removals have been recorded in the first half of 2026.

Gibraltar QROPS are often used by UK expats who prioritise regulatory familiarity (Gibraltar operates under a legal system closely aligned with UK law) and who may have connections to the Iberian Peninsula or are living in Spain or Portugal.

Tightening Compliance Requirements

A notable trend in 2026 is HMRC's increased scrutiny of scheme governance and reporting compliance. Several schemes — predominantly in smaller jurisdictions and emerging QROPS markets — have been removed from the recognised list following failures to comply with the enhanced reporting obligations HMRC implemented in late 2024 and early 2025.

These removals highlight a key lesson: the cheapest or newest QROPS offering is not always the safest. Schemes that have operated for many years, have robust administrator relationships with HMRC, and have a track record of regulatory compliance offer far greater security than newly-launched schemes with lower fees but limited track records.

Expanding Jurisdictions in 2026

Several jurisdictions have seen their QROPS offerings develop or expand in 2026:

New Zealand: New Zealand QROPS continue to be used by UK expats emigrating to Australasia. New Zealand's KiwiSaver schemes have historically met QROPS criteria, and the regulatory environment remains stable.

International Financial Centres: Jurisdictions such as the Isle of Man and Guernsey continue to host QROPS schemes, though with smaller scheme counts than Malta. These are sometimes preferred for their proximity to the UK regulatory environment.

European Jurisdictions: Following the OTC extension to EEA transfers in October 2024, QROPS in EU countries became subject to the Overseas Transfer Charge for most transfers. This has reduced the strategic advantage of EU-based QROPS for many expats, though they remain recognised and valid for specific use cases.

The Overseas Transfer Charge: Critical Context for List Users

Understanding the QROPS list means understanding the Overseas Transfer Charge (OTC). Introduced in March 2017, the OTC is a 25% charge applied to the transfer value when you transfer to a QROPS outside qualifying conditions. In October 2024, the exemption for EEA-based QROPS was removed, meaning the OTC now applies to most transfers to QROPS abroad unless:

• You are resident in the same country as the QROPS at the time of transfer, or
• Both you and the QROPS are in qualifying territories under specific treaty provisions

The removal of the EEA exemption fundamentally changed the QROPS landscape. For many expats living in EU countries, a QROPS transfer is now subject to a 25% upfront charge — making an International SIPP a more attractive option in many cases.

This makes the jurisdiction of both the QROPS scheme and your own residency critical when reviewing the HMRC list. A scheme being on the list does not mean a transfer is free of charge — the OTC may still apply depending on your circumstances.

Due Diligence Beyond the List

Even with a scheme on the HMRC recognised list, proper due diligence requires looking beyond the list itself:

Check scheme governance: Who manages the scheme? What is the track record of the administrator and trustee? Have there been any regulatory sanctions or complaints?

Review investment options: Does the scheme offer appropriate investment choices for your needs? Are costs transparent and competitive?

Understand fee structures: QROPS fees vary widely. Some schemes charge initial transfer fees, annual management fees, and exit charges. All fees should be disclosed in full before you transfer.

Verify the adviser: The adviser recommending a QROPS must be authorised to give pension transfer advice. In the UK, this means FCA authorisation; overseas advisers should hold appropriate local regulatory licences.

Confirm the OTC position: Before transferring, obtain written confirmation from your adviser of your OTC position — whether the charge applies, why it does or does not, and what protections exist if your circumstances change within five years of the transfer.

How to Check the Current QROPS List

The HMRC QROPS list is published on GOV.UK and is searchable by jurisdiction. To check whether a specific scheme is currently recognised:

1. Go to GOV.UK and search for "recognised overseas pension schemes"
2. Find the current list (updated fortnightly)
3. Search for the scheme by name or jurisdiction
4. Note the date the list was published — if it is more than a few weeks old, recheck for updates before proceeding

Your adviser should also be checking scheme status as part of their suitability assessment. If an adviser recommends a specific QROPS without confirming its current status on the HMRC list, that is a significant due diligence failure.

What to Do if Your Scheme Is Removed

If a QROPS scheme you have already transferred to is removed from the recognised list:

• You will typically receive notification from the scheme administrator
• Transfers already completed are generally not subject to retrospective OTC charges — the OTC is assessed at the time of transfer
• Future payments from a delisted scheme may be treated differently by HMRC for reporting purposes
• Seek specialist advice immediately to understand your options, which may include transferring to a replacement recognised scheme

Practical Guidance for Expats Considering a QROPS Transfer

1. Always check the current GOV.UK list immediately before any transfer proceeds — not just at the initial planning stage
2. Use a regulated adviser with specific QROPS expertise and HMRC compliance knowledge
3. Prioritise established schemes with track records over cheaper new entrants
4. Confirm your OTC position in writing before signing any transfer paperwork
5. Understand your scheme's governance, fees, and investment options fully before committing
6. Review the list again six months after transfer to confirm your scheme remains recognised

The 2026 QROPS landscape rewards careful due diligence and penalises shortcuts. The expanding range of recognised schemes in established jurisdictions gives expats good choices — but only if those choices are made with proper advice and up-to-date information.