If the government does think that further transfers to NMPA 55 schemes are not possible, it is effectively saying under historic rules it has not been possible to transfer from NMPA 55 schemes to NMPA 50 schemes.

It also does not make a great deal of sense to prevent members from consolidating their pensions on this basis. 

It is possible to transfer in the other direction, so why not from an NMPA 57 scheme to an NMPA 55 scheme?

I suspect the cause of the confusion is that, if someone had not joined a scheme before November 4 2021 then, unless they had started a transfer before that date, it became too late to initiate one.

So the closure of the transfer window was in fact a closure of a ‘joining window’.  

If your client was a member of an NMPA 55 scheme before November 4 2021, they can transfer other benefits to it and inherit the right to take benefits from that earlier age, just like the old NMPA rules.

However, if your client was not a member of an NMPA 55 scheme by that date, they would fail to meet the membership/joining requirement, thereby losing the opportunity to gain the NMPA of 55.

While the rules around the increase in NMPA do not have a direct impact until 2028, it is important to consider how the rules work on transfers with immediate effect.

This is to ensure your clients have the opportunity to benefit from as much flexibility as possible, even if they may not currently be planning to take benefits before reaching 57.

Gareth James is head of policy at AJ Bell