Annual Pension Review: A Checklist for Expat Pension Holders

A pension is not a set-and-forget arrangement. Markets move, rules change, life circumstances evolve, and the strategy you put in place three years ago may no longer be optimal. For expat pension holders — managing UK pensions whilst resident overseas, navigating international tax treaties, and potentially holding multiple pension schemes in different jurisdictions — the consequences of neglect are greater still.

Every year we sit down with our clients to work through a structured review. We have distilled that process into the twelve-point checklist below. Whether you work with us formally or are reviewing your own position, this framework covers the questions that matter.

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The 12-Point Annual Pension Review Checklist

1. Fund Value Check

Begin with the basics: what is your pension pot actually worth today, and is it on track to deliver the retirement income you need?

Compare your current fund value against the projection in your last financial plan. Most projection models assume a level of real return — typically 3–5% above inflation — and if actual growth has fallen short for two or more consecutive years, the shortfall compounds over time. Run a fresh retirement income projection using current values, your planned retirement date, and a realistic assumed drawdown rate. If there is a shortfall against target, the annual review is the moment to address it — through increased contributions, later retirement, or adjusted income expectations.

2. Investment Performance Review

Review how your pension funds have performed against their stated benchmarks over one year and three years. Short-term underperformance is not necessarily concerning — market conditions affect all managers — but funds that have persistently lagged their benchmark or peer group over three or more years warrant scrutiny.

Key questions: Has the fund manager changed? Has the fund's strategy or mandate shifted? Are charges significantly higher than comparable alternatives? One poor year is noise; three poor years is a signal. We review each fund against its benchmark and sector quartile ranking and make a recommendation to switch if the case for change is compelling.

3. Asset Allocation Review

Your asset allocation — the split between equities, bonds, cash, property, and other assets — should reflect your current age, risk tolerance, time horizon to retirement, and income needs. These factors change each year as you age and circumstances evolve.

Check whether your current allocation matches your intended allocation. Has drift occurred — has a strong equity run left you more aggressive than intended? Conversely, are you holding too much cash or too many bonds for your time horizon? Refer to your written investment policy statement, or work with us to create one if you do not have it. Rebalancing back to target allocation annually is a discipline that improves long-run risk-adjusted returns.

4. Contribution Level Review

Maximising pension contributions during your working years is one of the highest-return decisions available to you. Check whether you are making full use of your annual allowance — currently £60,000 per tax year, or 100% of UK earnings if lower.

If you have not contributed the maximum in recent years and were a member of a registered pension scheme during those years, you may be able to use carry-forward to make larger contributions now. Carry-forward allows unused allowance from the previous three tax years to be deployed in the current year. This is particularly valuable before a business exit, a bonus, or another large taxable income event. For expats with limited UK earnings, the £3,600 gross contribution limit (regardless of earnings) still applies for some non-earners — check eligibility.

5. Expression of Wishes

Your Expression of Wishes — the form held by your pension provider nominating your beneficiaries — does not form part of your will and does not pass through probate. It is a separate, critical document.

Review it each year. Has a named beneficiary died? Have you divorced or separated from a named spouse or partner? Have new children or grandchildren been born? Are the percentage splits still as you intend? An outdated Expression of Wishes can result in your pension passing to an ex-spouse or being distributed in a way that no longer reflects your wishes. Updating it takes minutes; failing to update it can have permanent consequences.

6. National Insurance Record

Your entitlement to the UK State Pension depends directly on your National Insurance contribution record. Thirty-five qualifying years deliver the full new State Pension (currently £241.30 per week in 2026/27, £230.25 in 2025/26). Years in which NI contributions are not made — through overseas employment, career breaks, or self-employment gaps — do not count.

Log into the UK Government's Personal Tax Account (accessible at gov.uk) at least once a year to check your NI record and your current State Pension forecast. If you have gaps, assess whether voluntary Class 2 or Class 3 NI contributions are worth making. For most expats with gaps in their record, voluntary contributions are exceptional value — but the break-even analysis depends on your life expectancy assumptions and planned retirement age. Do this check every year, particularly because the deadline to fill older gaps changes periodically.

7. State Pension Forecast

Related to the NI check above — but worth treating as a separate agenda item. Review your State Pension forecast, which projects your entitlement based on your current record and assumed future contributions.

Expats should note that the State Pension is frozen in certain countries — you will receive the State Pension at the level applicable when you first claim, with no subsequent uprating by the triple lock. Frozen countries currently include Australia, Canada, New Zealand, and others. If your retirement country is a frozen State Pension jurisdiction, this affects the income planning assumptions materially. UK, EU, and EEA residents receive uprated State Pension payments.

8. Double Taxation Agreement Status

If you are a UK expat receiving pension income, you should be receiving it under the appropriate double taxation agreement (DTA) between the UK and your country of residence. Most DTAs provide that private pension income is taxed exclusively in the country of residence — meaning HMRC should not be deducting UK income tax at source.

To achieve this, you need a valid NT (No Tax) code in force with your pension provider. NT codes are granted by HMRC following a Form DT Individual application countersigned by your local tax authority. They can lapse, and they do not automatically transfer when you move country.

Each year, verify with your pension provider that the correct tax code is being applied to your pension payments. If you have moved country and not updated your DTA claim, you may be paying UK tax unnecessarily — and the recovery process, while possible, is time-consuming.

9. QROPS Reporting Obligations

If you transferred a UK pension to a Qualifying Recognised Overseas Pension Scheme (QROPS) at any point, you face ongoing reporting obligations to HMRC. For transfers made on or after 6 April 2017, the key rule is the ten-year reporting period: any payment from the QROPS must be reported to HMRC for ten complete tax years following the transfer (the period was five tax years for transfers made before 6 April 2017). The member-payment provisions — under which an unauthorised payment charge can apply to payments inconsistent with UK pension rules — likewise apply for ten years of non-UK residence. The Overseas Transfer Charge can also apply where the transfer or a subsequent change of circumstances falls outside the exclusion conditions.

Track where you are on the ten-year reporting clock. If you are within that period, ensure your QROPS administrator is filing the required Event Reports with HMRC. If you have moved country since the transfer, assess whether the QROPS is still in a jurisdiction with a suitable DTA — because a QROPS transfer is in part defined by the country of residence and the scheme jurisdiction.

10. Annual Allowance and Carry-Forward

Revisit the annual allowance position. Even if you addressed this above in the contributions section, it is worth a dedicated line item — because unused carry-forward allowance expires after three years and unused capacity cannot be recovered.

Record in writing each year: (a) how much you contributed to all registered pension schemes in the current tax year; (b) how much remaining allowance you have; and (c) how much carry-forward is available from years three, two, and one back. This information becomes important in years when a large contribution is possible and needs to be deployed efficiently. For business owners, the corporation tax relief available on employer contributions adds another layer of planning to review annually.

11. Drawdown Rate Review

For clients already drawing income from a pension, the drawdown rate is the most important variable to reassess each year. A drawdown rate that was sustainable when your fund was £500,000 may not be sustainable if the fund has fallen to £380,000 following market volatility.

We model each client's drawdown position annually using three scenarios: base case (long-term average returns), pessimistic (returns 2% per annum below base), and stress test (a prolonged bear market in the early years of drawdown). If the pessimistic scenario shows the fund running out before age 90, the drawdown rate needs adjustment — either a reduction in withdrawals, a reallocation of assets, or consideration of whether partial annuitisation makes sense as a backstop income floor.

12. Tax Return and Self-Assessment

UK pension income — whether drawn from a UK SIPP, a UK defined contribution scheme, or the State Pension — is usually subject to UK income tax, regardless of where you live, unless a DTA provides otherwise. Even if your DTA provides for exclusive taxation in your country of residence, you may still have an obligation to report the income on a UK Self-Assessment return.

Each April, confirm whether you have a UK Self-Assessment obligation. If you have ceased to have UK taxable income under your DTA, you may be able to deregister for Self-Assessment — but this requires confirmation from HMRC. Failing to file a required return incurs automatic penalties. Keep this date in the diary.

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The Cost of Not Reviewing

Clients who disengage from their pension for five years or more frequently discover, when they re-engage, that they are behind target in ways that would have been correctable if caught earlier. A fund that has drifted into an inappropriate asset allocation for three years may have forfeited significant growth. An NT code that lapsed two years ago means two years of unnecessary UK tax deducted — which can be recovered, but only for a limited period, and not without effort.

Pension rules, allowances, and tax rates change regularly. HMRC processes change. DTA interpretations evolve. The annual review is the mechanism by which you keep pace with all of it.

How Global Investments can help

Our annual pension review service for expat clients works through exactly this checklist — and goes further where individual circumstances require it. We hold structured review meetings, typically by video call, with a written output document summarising findings, actions agreed, and projections updated. Between annual reviews, our clients have access to our pensions team for queries as they arise.

We do not take a passive approach to compliance: if an NT code needs renewing, we manage the process; if a QROPS reporting deadline is approaching, we coordinate with the scheme administrator. Please note that pension rules and tax treatment can change, and the information in this guide reflects our understanding as of June 2026 — readers should seek current professional advice before acting. Contact us to arrange your annual pension review.