A QROPS is a pension scheme outside the UK that HMRC accepts can receive a UK pension without a UK tax charge. Transfer to one that isn't, and your UK scheme may refuse, or you could pay at least 40% UK tax. HMRC does publish a list of NZ schemes, but being on it isn't proof. This post covers what the list shows, what it leaves out, and what to ask before you sign anything.
Invicta can advise on pension transfers, and a free 15-minute consultation is the place to start. This post is general information and a guide to the questions worth asking. It isn't a recommendation to transfer.
What is a QROPS in NZ?
QROPS stands for qualifying recognised overseas pension scheme. HMRC's Pensions Tax Manual says there are two parts to it. First, the scheme has to meet HMRC's requirements to be a recognised overseas pension scheme (a ROPS), which HMRC calls a factual test. Second, the scheme's manager has to notify HMRC that it meets them, and promise to provide information to HMRC, other schemes and members.
In NZ, that usually means a superannuation scheme that has been through that process. IRD's regulatory impact statement says KiwiSaver schemes ceased to be QROPS in 2015. So a provider's KiwiSaver scheme and a QROPS are different products, and the exact scheme name matters.
There's one exception. If you moved UK pension money into KiwiSaver before 17 June 2015, that locked-in money can move to a NZ QROPS. IRD says it has been able to since 1 April 2025.
How do you check a NZ scheme is a QROPS?
Start with HMRC's list. It's called the recognised overseas pension schemes notification list, and it's on GOV.UK. HMRC updates it on the 1st and 15th of each month, or the next working day. The last update was 1 October 2026, and the next is due on 15 October.
The New Zealand section has 37 entries. A number of them are numbered funds, so match the full scheme name, not just the provider's brand.
The list has limits, and HMRC says so itself.
The page says HMRC "cannot guarantee these are ROPS or that any transfers to them will be free of UK tax". The manual explains why. The list shows only that the manager told HMRC and asked to be listed. It doesn't show the scheme meets the requirements, and that can change after the notification.
Not every scheme chooses to appear on it either. If you can't find one, ask the scheme to confirm its status in writing.
The list also moves quickly. HMRC can take a scheme off for a while if it has concerns or can't contact the manager, and transfers made after a scheme stops being a ROPS aren't recognised transfers. That's why HMRC says to check the list no more than one day before the transfer.
What happens if the scheme isn't a QROPS?
GOV.UK says it's up to you to check, with help from the overseas scheme, your UK provider or an adviser. If the scheme isn't a QROPS, the UK scheme may refuse the transfer, or you'll pay at least 40% tax on it.
Being on the list doesn't fully protect you either. HMRC's manual says that if a scheme is listed but shouldn't have been, a transfer can mean a 40% unauthorised payments charge plus a further 15% surcharge for you, and a scheme sanction charge for the UK administrator. HMRC's list page also says it will usually pursue UK tax charges and interest even when a scheme appears on the list, and may charge penalties.
What should you ask a NZ scheme before you transfer?
These are the questions we'd want answered. We can help you work through the answers, and we'll tell you when you need specialist tax or UK advice.
- What's the full legal name of the scheme and its manager? Match it to HMRC's list, then look the provider up on the Financial Service Providers Register. The FMA says to deal with licensed providers, because you then have access to free dispute resolution. The register shows a provider's services and its dispute resolution scheme.
- Can you confirm in writing that the scheme meets the ROPS requirements today, and tell me if that changes?
- Do you offer scheme pays? IRD says QROPS must offer it from 1 April 2026. The tax is a flat 28%, and you give the scheme your assessable withdrawal amount within 10 working days of the transfer. Ask how it handles that deadline.
- What happens if I move away in the first few years? The UK's 25% overseas transfer charge can apply if you leave within five full UK tax years after the tax year of the transfer, so the window can last almost six years. Ask how the scheme would handle that and how you'd tell them.
- How do you apply the UK minimum pension age? It's 55 now and rises to 57 on 6 April 2028. Taking money out too early can trigger UK tax charges.
- Will I get written confirmation of whether the 25% charge applies, and why? HMRC tells the receiving scheme to keep that information for five tax years. Keep your own copy too.
If your UK pension has guarantees, such as a defined benefit pension, there's a UK step before any of this. For safeguarded benefits worth more than £30,000, you must take advice from an FCA-authorised adviser before you transfer. Our earlier guide, Transfer UK Pension to NZ in 2026, covers the NZ tax side, the UK charges and what you might give up.
Thinking about moving a UK pension?
If you have a UK pension and aren't sure whether moving it makes sense, or how it fits with your KiwiSaver, a free 15-minute consultation is the place to start. We can advise on pension transfers. Tax and UK pension rules can be complex, so we'll tell you when you need specialist tax or UK advice.
What's new this month?
We haven't found a change to the rules covered here since scheme pays started on 1 April. HMRC's latest list update, on 1 October, added 46 schemes and removed 7 across all countries, with no changes to the New Zealand section. The next one is due on 15 October, which is why a scheme's status on the day you transfer is the one that counts.
Where we can help
Our advisers can advise on pension transfers, as well as KiwiSaver, personal insurance, mortgage advice and wealth planning. We can review what you already have and compare the market. Every situation is different and a transfer won't suit everyone, so check the receiving scheme is a recognised QROPS before anything moves. Tax and UK pension rules can be complex, so we'll tell you when you need specialist tax or UK advice.
Not sure where a UK pension fits in the bigger picture?
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Sources
- HMRC, Check the recognised overseas pension schemes notification list (GOV.UK): https://www.gov.uk/guidance/check-the-recognised-overseas-pension-schemes-notification-list
- HMRC Pensions Tax Manual, PTM112400 (the published list of ROPS notifications): https://www.gov.uk/hmrc-internal-manuals/pensions-tax-manual/ptm112400
- GOV.UK, Transferring to an overseas pension scheme: https://www.gov.uk/transferring-your-pension/transferring-to-an-overseas-pension-scheme
- GOV.UK, Overseas pensions: pension transfers: https://www.gov.uk/guidance/overseas-pensions-pension-transfers
- IRD, Register for an overseas pensions transfer account: https://www.ird.govt.nz/kiwisaver/kiwisaver-scheme-providers/register-for-an-overseas-pensions-transfer-account
- IRD, Foreign superannuation transfers and the scheme pays option: https://www.ird.govt.nz/income-tax/income-tax-for-individuals/types-of-individual-income/foreign-superannuation/foreign-super-transfers-and-the-scheme-pays-option
- IRD, Transferring locked-in UK pension funds from KiwiSaver schemes: https://www.ird.govt.nz/kiwisaver/kiwisaver-individuals/making-changes-to-my-kiwisaver/transferring-locked-in-uk-pension-funds
- IRD, Regulatory impact statement on the taxation of transfers from overseas pension schemes (May 2024): https://www.regulation.govt.nz/assets/RIS-Documents/ris-ird-ttop-may24.pdf
- GOV.UK, Increasing normal minimum pension age: https://www.gov.uk/government/publications/increasing-normal-minimum-pension-age
- GOV.UK, Pension benefits with a guarantee and the advice requirement: https://www.gov.uk/government/publications/pension-benefits-with-a-guarantee-and-the-advice-requirement/pension-benefits-with-a-guarantee-and-the-advice-requirement
- FMA, Licensed and reporting entities: https://www.fma.govt.nz/business/licensed-providers/
- Financial Service Providers Register: https://fsp-register.companiesoffice.govt.nz/
General Information Disclaimer
The information in this article is general in nature and is not intended to be personalised financial advice. It does not take into account your individual goals, financial situation, needs, or circumstances
Any examples, figures, rates, or scenarios are for illustrative purposes only and may change over time.
Before making any financial decision, you should consider whether the information is appropriate for your circumstances and, where appropriate, seek personalised advice from a licensed financial adviser.
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