Every Finance Act is read as if it were one or two headline measures. In 2026, those measures were the pension inheritance tax reform (Chapter 4, sections 121–138) and the extension of the IHT threshold freeze (Schedule 11). The rest of the Act — eight chapters and eleven schedules — was reported lightly or not at all. A handful of those provisions will matter more in practice than the headline measures, at least for a meaningful subset of households.
Trust register expansion
Section 87 of the Act expands the Trust Registration Service to cover a wider range of bare trusts and informal trust arrangements that were previously outside the registration requirement. The expansion is technical, but the practical effect is to bring into the register many family arrangements — typically older trusts established without formal documentation — that have hitherto operated in the regulatory grey zone. Registration is required within ninety days of the Act's commencement for existing trusts caught by the new criteria; failure attracts a penalty regime under section 89.
The administrative burden falls primarily on solicitors and accountants, but ultimate responsibility rests with the trustees. Households who have an older trust arrangement — life-interest, bare, accumulation — and are unsure whether it is registered, should check; the cost of late registration is modest, but the cost of discovering at probate that the trust was unregistered is, in our experience, materially higher.
Charity reduced-rate clarification
Sections 156–159 amend Schedule 1A of the Inheritance Tax Act 1984 to clarify the operation of the reduced-rate charitable legacy provision in light of the inclusion of Notional Pension Property. The legislative drafting is dense; the substantive effect is that the baseline amount for the ten per cent test now expressly includes NPP, except where the NPP itself is the source of the charitable legacy. This was the technical question every private-client adviser asked when the pension reform was first announced. The Act answers it.
We covered the practical implications in 'The philanthropy barrier' (April 2026). The clarification is welcome; the resulting test is, as predicted, harder to satisfy than the pre-reform position.
Self-assessment digital filing
Sections 201–214 advance the Making Tax Digital programme to require quarterly digital updates from self-employed individuals with annual income above £30,000, from April 2027. The change is administrative rather than substantive — the tax position remains the same — but the operational impact on the cohort affected is significant. For estate-administration purposes, executors of self-employed deceased individuals will need to engage with the digital update history rather than the historical annual return; the executor's access to HMRC's digital records is a separate and often slower process.
What did not pass
Three provisions widely expected to feature in the 2026 Act did not. The first is reform of capital gains tax on death — the question of whether unrealised gains should be deemed disposed at death (creating a CGT charge) rather than passed at the date-of-death valuation (the current rebased position) has been live in academic and Treasury commentary for years; the 2026 Act did not address it. The second is reform of the seven-year potentially exempt transfer rule for lifetime gifts; the Tax Law Review Committee had proposed a shortening, the Act left it alone. The third is reform of the spousal exemption for cohabiting partners; the Law Commission has recommended reform repeatedly, no government has acted.
The absence of these provisions is itself worth noting. Each has been recommended by serious bodies for years; each remains untouched. The political economy of inheritance tax reform appears, at present, to favour quiet revenue-raising via freeze and base-broadening over visible structural change. The next five years are likely to look more like the last five than otherwise.