New Pension and Salary Sacrifice Changes: Key points

Written by Richard Baldwyn ATT, CTA
January 29, 2026

The new pension and salary sacrifice changes, announced in the Autumn 2025 Budget,will significantly change the National Insurance treatment of workplace pension contributions from 6 April 2029. 

New Pension and Salary Sacrifice Changes

Under the new rules, only the first £2,000 of employee pension contributions made through salary sacrifice each year will remain exempt from National Insurance contributions.

In this article, we explain what is changing, who will be affected, how the new rules will work in practice, and what steps you should consider taking now.

Pension Salary Sacrifice Changes: An Overview

Despite widespread speculation ahead of the Autumn 2025 Budget, the government chose not to introduce a cap on pension salary sacrifice contributions. Consequently, this means the Annual Allowance, currently £60,000 for most individuals, remains the main limit on tax-relieved pension savings

Instead, the New Pension and Salary Sacrifice Changes focus on tightening the rules around:

  • How salary sacrifice arrangements are structured.
  • How they are documented.
  • How National Insurance savings are calculated.
  • How contributions are reported to HMRC.

What Is Salary Sacrifice?

A Salary Sacrifice arrangement is where an employee agrees to surrender part of their gross salary in return for a non-cash benefit. In most cases today, this benefit is an employer pension contribution, as HMRC has largely restricted salary sacrifice for other types of benefits.

This method is widely used because it reduces both income tax and employee National Insurance contributions (NICs).

The pension contribution is normally made directly by the employer and is generally deductible when calculating the company's taxable profits, subject to the usual rules.

  • Firstly, employees save income tax and National Insurance.
  • Secondly, employers save employer’s National Insurance.
  • Additionally, pension contributions are usually deductible for corporation tax.
  • Lastly, the sacrificed salary is not treated as taxable earnings.

However, HMRC requires clear evidence that these arrangements are properly implemented and not used artificially. As a result, we expect increased scrutiny once the New Pension and Salary Sacrifice Changes take effect, particularly where:

  • Large pension contributions are made at year-end.
  • Directors take very low salaries but receive substantial pension funding.
  • Arrangements appear commercially unjustified.

We discuss directors in more detail below.

How the Pension Salary Sacrifice Changes Work from April 2029

From 6 April 2029, a new limit will apply to the National Insurance savings generated through pension salary sacrifice.

The key change

Employees will be limited to £2,000 per tax year in employee National Insurance savings arising from salary sacrifice pension arrangements.

This is not:

  • A cap on pension contributions.
  • A cap on salary sacrifice amounts.

Once the £2,000 NIC saving limit is reached, any further sacrificed salary will become subject to Class 1 National Insurance for both the employee and the employer.

An example Employee on £60,000 salary

Let’s take John, who earns £60,000 a year and chooses to sacrifice £5,000 of his salary into his workplace pension.

Before 6 April 2029

Under the current rules, the full £5,000 salary sacrifice can generally be made free of employee and employer National Insurance, provided the salary sacrifice arrangement is valid.

From 6 April 2029

Under the new rules:

  • the first £2,000 of salary sacrificed into the pension will remain exempt from National Insurance;
  • the remaining £3,000 will be subject to employee and employer NICs; and 
  • the pension contribution itself can still be made, so the £2,000 limit is not a cap on the amount that can be contributed to the pension.

Therefore, larger pension salary sacrifice arrangements will become less National Insurance-efficient from April 2029, although salary sacrifice will continue to offer benefits.

Who Will Be Affected by the Pension Salary Sacrifice Changes?

These changes will not impact everyone equally. Those most likely to notice a difference include:

  • Employees sacrificing more than £2,000 per year into pensions.
  • Higher earners using salary sacrifice to manage tax bands.
  • Individuals aiming to preserve the personal allowance or their entitlement to Child Benefit.
  • Employers who share their NIC savings with employees.
  • Businesses using salary sacrifice as a major part of remuneration strategy.

However, employees making modest contributions are unlikely to see any material change.

Do the Pension Salary Sacrifice Changes Affect Directors?

Importantly, the new £2,000 limit relates to employee pension contributions made through salary sacrifice. It should therefore be distinguished from a company making an employer pension contribution directly for a director.

For many owner-managed companies, direct employer pension contributions may continue to form part of remuneration planning without involving salary sacrifice at all. However, the normal rules governing employer pension contributions, including the Corporation Tax rules and pension annual allowance, still need to be considered.

In these situations, there may be no salary sacrifice at all, meaning the new NIC cap may not apply.

Directors are office holders rather than employees, and HMRC often views their remuneration differently. However, HMRC has not yet issued detailed guidance on how the New Pension and Salary Sacrifice Changes will apply to director-owners.

We expect HMRC to pay closer attention to:

  • Whether pension contributions reflect genuine remuneration for work performed.
  • Arrangements involving family members.
  • Commercial justification for contribution levels.
  • Consistency of remuneration strategy.

Consequently, careful structuring and documentation remain essential.

What action should you take now?

Although the new rules do not take effect until 2029, investing in pensions is a long-term strategy. Therefore you should consider:

  • Model future National Insurance costs where salary sacrifice exceeds £2,000.
  • Review existing salary sacrifice agreements and employment contracts.
  • Confirm whether current pension funding is true salary sacrifice or standard employer contribution.
  • Revisit remuneration planning for directors and key staff.
  • Ensure documentation is robust and up to date.

Pension Salary Sacrifice Changes: Key Takeaways

The New Pension and Salary Sacrifice Changes do not introduce contribution caps. Although, they do significantly change how National Insurance savings will be treated from April 2029.

For most employees making regular pension contributions, the impact will be limited. However, higher earners and businesses using salary sacrifice extensively will need to review their approach

Additionally, director-owners should continue to ensure pension contributions reflect commercial reality and are properly structured, particularly as HMRC scrutiny is likely to increase.

For more useful information, check out our Ebooks here.

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About the author

Richard Baldwyn ATT CTA

Richard is Co-Founder of The Friendly Accountants and has more than 30 years' experience in tax, including 3 years spent inside HMRC before moving into private practice. He advises individuals and owner-managed businesses on a wide range of UK tax issues, including the tax challenges created by digital platforms and online business models.

Richard has specialised in UK crypto taxation since 2016 and was one of the first UK tax advisers to write publicly about the taxation of cryptoassets. His work includes advising individuals, investors, founders and owner-managed businesses on complex crypto transactions, HMRC disclosures and enquiries, DeFi, NFTs and the tax issues facing businesses operating with digital assets.

He also has first-hand experience of cryptoassets and Web3 projects, combining practical knowledge of how crypto is used with wider UK tax experience.

He particularly enjoys making complex tax transactions easier to understand and helping clients apply tax rules to transactions and technologies that do not always fit neatly within traditional tax categories. More about Richard and the TFA team

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