If you are a UK expat living overseas or considering retirement abroad, you may already have come across the term QROPS. Standing for Qualifying Recognised Overseas Pension Scheme, QROPS has long been a central part of pension planning for British nationals abroad. But what exactly is the QROPS list and why does it matter so much?

The QROPS list is a notification list of schemes that have notified HMRC (told HMRC) they meet the requirements to be recognised as overseas pension schemes. Inclusion on the list is based on ROPS notifications, where schemes have formally told HMRC of their status, but this does not guarantee ongoing approval.

This guide brings together all the information expats need about the QROPS list, including how schemes are notified to HMRC, the role of the notification list, and how ROPS notification and ROPS notifications work. We will also look at the five year and ten year rules for QROPS, the tax implications, and the alternatives available today.

Introduction to QROPS

A Qualifying Recognised Overseas Pension Scheme (QROPS) is a specific type of overseas pension scheme that meets the strict criteria set by HM Revenue & Customs (HMRC). These schemes are designed to allow individuals with UK pension funds to transfer their savings abroad, typically to support retirement plans for UK expats. By transferring to a recognised overseas pension scheme, individuals can potentially benefit from more flexible pension options and, in certain circumstances, reduce their exposure to UK tax charges.

The HMRC QROPS list is a vital tool for anyone considering such a transfer. Updated twice monthly, this list identifies which overseas pension schemes have self-certified as meeting HMRC’s requirements and are therefore eligible to receive transfers from UK pension schemes. Using the QROPS list helps ensure that your pension funds are transferred to a qualifying recognised overseas pension, reducing the risk of unexpected tax liabilities and ensuring compliance with UK customs and tax regulations. For anyone looking to manage their pension savings internationally, understanding the QROPS list and the requirements for recognised overseas pension schemes is essential.

Understanding the QROPS Scheme in the UK

A QROPS is a type of overseas scheme that meets requirements set by HM Revenue & Customs (HMRC). Only recognised overseas pensions schemes (ROPS) are eligible for transfers from UK pensions. If it appears on the official QROPS list published by HMRC, it means the scheme has self-certified that it complies with UK standards for transferring pensions abroad, but it is the individual’s responsibility to verify the scheme’s ongoing compliance and to understand the scheme rules that govern eligibility and withdrawals.

The scheme allows expats to transfer their UK pension into a qualifying overseas fund, often with the aim of reducing tax exposure, accessing more flexible investment options, or simplifying retirement income if you live outside the UK. The UK pension provider will require specific forms and documentation, such as Form APSS263, to process a transfer to a recognised overseas pensions scheme.

Common questions include:

• What is the difference between QROPS and SIPPs? A Self-Invested Personal Pension (SIPP) is a UK-based pension that offers flexibility but keeps your funds within the UK. A QROPS moves your funds offshore, subject to local tax rules.
• What happens to your UK pension if you move abroad? You can leave it in the UK, transfer to a SIPP, or transfer to a QROPS if a suitable jurisdiction is available.
• Can I transfer my Australian or New Zealand pension to the UK? Transfers into the UK are possible but must follow strict HMRC and local rules. The reverse is more common: UK pensions transferred overseas.

The main reasons expats consider a QROPS are tax efficiency, flexible access, and the ability to manage retirement income abroad. However, there are risks involved, such as potential tax charges, regulatory changes, and scheme security issues. It is your responsibility to check the scheme rules, ensure the overseas scheme is a recognised overseas pensions scheme, and verify compliance to avoid future problems.

HMRC Recognition and Requirements

For an overseas pension scheme to be recognised by HMRC as a QROPS, it must satisfy a set of requirements designed to protect pension savers and ensure compliance with UK tax rules. The scheme administrator is responsible for notifying HMRC that the scheme meets all necessary criteria, including being established in an approved jurisdiction and adhering to local tax authority regulations. Once notified, the scheme may be included on the HMRC QROPS list, which is published twice a month to provide up-to-date information for advisers and pension members.

It’s important to note that inclusion on the HMRC QROPS list does not mean the scheme is approved or endorsed by HMRC. The list simply indicates that the scheme has declared itself as meeting the requirements for QROPS status at the time of notification. Ongoing compliance is not guaranteed, and schemes can be removed from the list if they no longer meet HMRC’s standards. Therefore, anyone considering a transfer should always check the most recent QROPS list and seek professional advice to ensure the receiving scheme maintains its recognised status.

Eligibility Requirements for QROPS

To appear on the HMRC QROPS list, a pension scheme must first qualify as a Recognised Overseas Pension Scheme (ROPS). This involves meeting a series of eligibility requirements, including the tax recognition test, regulatory requirements test, and pension age and benefits tax relief test. The scheme must be established in a jurisdiction approved by HMRC and must comply with all relevant UK legislation and HMRC requirements for QROPS status.

Maintaining QROPS status requires ongoing adherence to these standards, and schemes are subject to regular review. Because the rules can be complex and may change over time, it is highly recommended to seek professional advice from a qualified financial adviser before transferring your pension. This ensures that your chosen overseas pension scheme remains compliant, that you benefit from available tax relief, and that your pension funds are protected from unnecessary UK tax charges. By understanding the eligibility requirements and consulting with experts, you can make informed decisions about your pension benefits and avoid costly mistakes.

The QROPS List Explained

The QROPS list is an HMRC-published register of overseas pension schemes that have self-certified as compliant. It is updated twice a month and includes schemes from jurisdictions such as Gibraltar, Malta, and the Isle of Man. The HMRC list is published on set dates each month, and if the publication date falls on a weekend or UK public holiday, the update is released on the next working day.

Importantly, the list is not a guarantee. HMRC does not approve, endorse, or regulate QROPS funds. It simply confirms that the scheme has declared itself eligible. Expats must therefore conduct due diligence before transferring any pension.

Some countries have lost QROPS status in recent years. For example, Australia and New Zealand once had many schemes, but after HMRC tightened regulations, most were removed. HMRC may temporarily remove schemes from the HMRC list at short notice, for example, if there is suspected fraudulent activity or compliance concerns. Superannuation funds in countries like Australia are sometimes included or removed, and transferring to a scheme not on the HMRC list can result in unauthorised payments and a scheme sanction charge. Today, options are more limited, which is why many expats are now considering alternatives like international SIPPs.

Isle of Man Schemes and Other Jurisdictions

The Isle of Man is a leading jurisdiction for QROPS, known for its robust regulatory environment and favourable tax treatment of pension schemes. Alongside the Isle of Man, other popular jurisdictions such as Malta and Gibraltar also offer recognised overseas pension schemes that appear on the HMRC QROPS list. Each jurisdiction has its own rules and tax implications, so it’s important to carefully consider where your pension savings will be transferred.

When evaluating overseas pension schemes, factors such as local tax rates, regulatory protections, and compliance with HMRC requirements should all be taken into account. Working with a professional financial adviser who specialises in QROPS transfers can help you navigate these complexities, ensuring your pension transfer is both tax-efficient and compliant with UK and local regulations. By understanding the options available in jurisdictions like the Isle of Man and seeking expert advice, you can make the most of your pension savings while minimising the risk of unexpected UK tax charges.

Is QROPS a Good Idea in 2025?

The short answer is: it depends on your circumstances.

QROPS were once considered the go-to solution for British expats. They allowed access to pension savings without UK tax restrictions, offered currency flexibility, and in some cases allowed for better estate planning.

However, since the introduction of the overseas transfer charge in 2017, many of the tax advantages have been reduced. The overseas transfer allowance now limits the amount that can be transferred to a QROPS without incurring additional UK taxes; exceeding this allowance may result in tax charges. Unless you are resident in the same country as your chosen QROPS, or within the European Economic Area, a 25 per cent tax charge may apply.

Questions you should consider:

• Do you live in a jurisdiction where QROPS are still available?
• Are the costs and fees justified compared to a UK-based SIPP?
• Could you benefit more from the protection and regulation of keeping your funds in the UK?
• Can you benefit from the tax benefits of a QROPS, such as receiving a lump sum or ongoing pension income with reduced taxes?

The Five-Year and Ten-Year Rules for QROPS

Many expats are confused by the five year rule for QROPS. This relates to HMRC monitoring of your pension for the first five UK tax years after transfer. During this period, certain withdrawals or benefits must still meet UK rules, even if you live abroad. These rules apply to both your UK pension scheme and, in some cases, your UK state pension.

There is also the ten year rule, which applies to reporting requirements. Some schemes must continue to report payments to HMRC for ten years after the transfer. Scheme rules may require ongoing reporting for both private and state pension benefits. This ensures HMRC can track potential UK tax liabilities.

Tax Considerations

One of the most common questions is: Do I have to pay tax on overseas pensions?

The answer depends on where you live. For example:

• In Australia, you may face local tax rules on pension income.
• In Malta, tax treaties may help reduce double taxation.
• In some jurisdictions, pension income is not taxed at all.

Some overseas pension schemes may be free of UK tax if the scheme qualifies under HMRC rules, but it is important to verify this before transferring.

Always check the double taxation agreement between the UK and your country of residence.

Alternatives to QROPS

With fewer countries offering QROPS today, many expats are looking at alternatives. The most popular is the international SIPP, which keeps your pension under UK regulation but offers global investment access, currency options, and flexible income drawdown. If you are considering a QROPS transfer, you should contact the QROPS provider to confirm they will accept your pension fund and to understand the transfer process.

This often provides the best of both worlds: regulatory protection from the UK combined with expat-friendly flexibility.

FAQs – What is the QROPS List?

When can I withdraw my QROPS? You can typically access funds from age 55, rising to 57 in 2028, in line with UK pensions.

Can I transfer my pension to a bank account? Yes, once withdrawals are permitted, you can have income paid into your overseas bank account.

Which countries still offer QROPS? Popular jurisdictions include Gibraltar, Malta, and the Isle of Man. The list of available countries is published in the HMRC notification list of overseas pension schemes ROPS, which is updated regularly to reflect current scheme recognition and compliance.

Is QROPS tax free? Not necessarily. It depends on the country where your QROPS is based and your country of residence.

Who regulates QROPS? Local regulators in the jurisdiction where the scheme is based. HMRC only maintains the list but does not supervise.

Conclusion: Do You Still Need the QROPS List?

The QROPS list remains an important resource for UK expats, but it is no longer the silver bullet it once was. With fewer options and new tax charges, many expats may be better served by an international SIPP or other expat wealth management solutions.

Before making a decision, it is crucial to seek transparent, fee-based advice tailored to your personal circumstances.

Get in touch

If you are unsure whether a QROPS transfer is right for you, speak with an independent adviser. At Harrison Brook, we help British expats around the world make informed decisions about pensions, investments, and retirement planning.

Contact us today to explore your options and ensure your financial future abroad is secure.