Some individuals will already have had a certificate for more than 90 days, or already had their first RBCE. Although the regulations are effective from April 6 2024, these obligations only begin from November 18 2024.

For personal representatives of deceased individuals, there are also changes to the deadline to apply for a certificate.

Currently, a certificate must be applied for before the individual’s first RBCE, but this deadline will be extended in respect of deceased members to October 31 following the end of the tax year in which a relevant lump sum death benefit is paid.

This removes some pressure from personal representatives and gives time to understand whether a certificate would be beneficial.

Bethany Joslyn is a senior technical consultant at AJ Bell