27 November 2025
Yesterday’s budget brought potential changes to Pension Salary Sacrifice (or Exchange) – essentially capping the Employer and Employee National Insurance saving to the first £2,000 per annum sacrificed.
The changes are scheduled to commence on 6th April 2029, but there are some considerations that your business and your employees need to think about in the interim.
The headlines
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£2,000 annual cap on NIC savings on Pension Salary Sacrifice contributions from April 2029.
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For example, for an employee sacrificing £5,000 per annum - this means potentially an additional £450 per annum in National Insurance costs for employers at the current 15% rate. Employees would lose £60-£240 per annum in savings based on the same £5,000 per annum contribution.
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The Salary Sacrifice cap would still save employers £300 per annum and employees would still benefit from £40-160 per annum. Employees would also still benefit from tax relief at their highest marginal rate - as well as avoiding punitive tax thresholds at both £60-80,000 (when claiming Child Benefit) and above £100,0000 of annual earnings. For contributions to relief at source schemes, Pension Salary Exchange also avoids the need for higher rate taxpayers to reclaim higher tax relief.
Employer considerations
In terms of the high-level things to be thinking about, we suggest:
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Map your exposure - who uses Pension Salary Sacrifice, at what levels and in which business units / entities?
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Identify any "NIC recycling" commitments - have you made formal or informal promises to share employer NIC savings with staff to boost pension contributions?
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Use the window - changes are not scheduled until 2029 (and ultimately may not happen), so employees should think about maximising savings between now and then.
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Bonus sacrifice - think about promoting for the current and following three years to utilise the savings before any rule changes.
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Audit your wording - employment contracts, sacrifice agreements, handbooks and scheme rules: are your agreements robust and are potential changes in the law covered?
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Scenario test the reward cost - what might happen to your total compensation budget assuming this becomes a reality?
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Think about your contribution structure – might there be an argument to move towards a non-contributory pension scheme in advance of April 2029?
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What are the practicalities? what options will you have from a payroll perspective to embrace the legislation when it comes?
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Communicate with your employees - so you can explain to employees that any changes are driven by legislation, but that a window of opportunity exists.
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Speak to your professional advisers - talk through how the above affects your business and your employees, and create a plan.
Thankfully there were no immediate changes to what can be paid into pensions and the tax position of benefits at retirement.
Other changes to be aware of
From April 2026
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The New State Pension - The full flat rate will increase from £230.25 at present to £241.40 a week - or just under £12,548 a year.
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There were expected changes to Minimum Wage requirements, albeit the 8.5% increase for 18-20 Year Olds was significantly higher than the 4.1% rise for those over 21 – link here
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Given the difference in return between Stocks and Shares ISA when compared to the Cash equivalent, we will see a restriction of investment into Cash ISAs to £12,000 per annum, although the annual total will remain at £20,000 per annum. What is your employer position regarding Workplace ISAs and might you want to amend that position? Tax on dividend income will increase by 2 percentage points at the start of the next tax year, with further increases to both savings income and property income announced from April 2027.
For the future
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Fiscal drag has been extended. The current income tax thresholds will be maintained until at least the beginning of the 2031 tax year, so whilst your employees might expect pay rises during this time, they will end up paying more tax and National Insurance on the whole.
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Electric Vehicle Excise Duty (eVED) was announced: this is a new mileage charge for electric and plug-in hybrid cars, which will take effect from April 2028. The government is commencing a consultation regarding how eVED will work but the headlines are that drivers of electric cars will pay a road charge of 3p per mile, while plug-in hybrid drivers will pay 1.5p per mile.
We will be releasing a more detailed guide, with practical guidance in the coming week – but if you have any immediate concerns please contact your Verlingue consultant or contact us via the enquiry form
Based on Verlingue’s understanding of current tax law, pension legislation and HM Revenue and Customs’ practice November 2025. Investments can fall as well as rise, irrespective of the level of risk chosen, and the value of an investment and any income generated from it can go down as well as up. Past Performance is not a reliable indicator of future results. Tax rules may change and will apply to your individual circumstances. Employees should seek independent financial advice.
