Transfer an ISA if you're an ISA manager
Source: gov.uk (2025-03-27)

Find out when you can transfer an ISA and what information you need to provide to the new ISA manager.

Transferring an ISA

Investors have the right to transfer their Individual Savings Account (ISA) whenever they want. This right must be included in your ISA terms and conditions.

They do this by making a transfer application to the new manager. They cannot transfer an ISA by closing it and paying the proceeds into a new ISA with the new ISA manager.

If the ISA is a Lifetime ISA:
- the tax-free wrapper will be removed
- the transfer will be treated as a withdrawal, so may be liable to a withdrawal charge
Transfer rights for non-cash Innovative Finance ISA investments are set out in the terms and conditions of the account. There are no restrictions when transferring funds held in cash and stocks and shares ISAs to Innovative Finance ISAs.

A transfer application can be made by someone holding a mandate from the investor.

These transfers are allowed:

subscriptions can be transferred freely between cash, stocks and shares, and innovative finance ISAs

subscriptions to a Lifetime ISA can be transferred to cash, stocks and shares and innovative finance ISAs, but will be treated as a withdrawal and may be liable to a withdrawal charge

subscriptions to a Lifetime ISA can be transferred to another Lifetime ISA without incurring a withdrawal charge

funds held in cash ISAs, stocks and shares ISAs, and cash held in Innovative Finance ISAs may be transferred to Lifetime ISAs — the amount transferred must not exceed the annual Lifetime ISA subscription limit

Transfer process

ISA managers are not obliged to accept transfers-in.

The terms of a transfer should be agreed between:
- the investor
- you, as the old ISA manager
- the new ISA manager
When an ISA is transferred, all the tax benefits are preserved.

Subject to the ISA terms and conditions of both ISA managers, you may transfer:
- the ISA investments, in which case the new manager must re-register the investments in accordance with their terms and conditions — read what you need from investors when they apply for an ISA (https://www.gov.uk/guidance/information-you-need-from-investors-when-they-apply-for-an-isa)
- cash
- any combination of these
Investments and cash transferred are not new subscriptions for the purposes of the overall subscription limit. If transferred into a Lifetime ISA, they may be eligible for a government bonus and may contribute towards the Lifetime ISA threshold.

Read ‘Lifetime ISAs for ISA managers (https://www.gov.uk/guidance/lifetime-isas-for-isa-managers)’ to find out how the transferred amount will be treated for the government bonus.

You must transfer the investments and cash direct to the new ISA manager. If you transfer them to the investor, this will be treated as a withdrawal, so the investments and cash will lose their tax-free wrapper. If they have been transferred out of a Lifetime ISA, there may be a withdrawal charge.

Find out how to manage ISA subscriptions for your investors (https://www.gov.uk/guidance/manage-isa-subscriptions-for-your-investors).

You must keep a record of ISAs you transfer-out, including either:
- the original or certified copy of the applications, if the application was made in writing
- the declaration you made for 3 years after the date of transfer, if the application was not made in writing
Find out more about what you need from investors when they apply for an ISA (https://www.gov.uk/guidance/information-you-need-from-investors-when-they-apply-for-an-isa).

What amounts can be transferred

An investor must do one or both of these:
- transfer some or all of the current year’s ISA subscriptions, the investments bought with those subscriptions, and any income arising on those investments
- transfer some or all of the previous years’ ISA subscriptions, the investments bought with those subscriptions, and any income arising on those investments
Specific ISA types

Lifetime ISA

When subscriptions from the current or previous year are transferred to another Lifetime ISA, the government bonus must also be transferred.

Non-Lifetime ISAs to Lifetime ISAs

For transfers of subscriptions from non-Lifetime ISAs to Lifetime ISAs, only subscriptions (including any related income) which do not cause the Lifetime ISA limit to be exceeded may be transferred.

Find out more about reporting transfers-in annual returns of information (https://www.gov.uk/guidance/annual-returns-and-tax-claims-for-isa-managers).

ISAs with investments

The value of the investments must be treated as being anywhere between 2 limits if both:
- they are current year subscriptions in a cash or investment ISA
- their value is unknown
The 2 limits are the total amount subscribed in the current year:
- plus a reasonable apportionment of the income from that subscription (upper limit)
- less withdrawals made in the year (lower limit) — if the withdrawals exceed subscriptions, the lower limit is £0
All cash and investments held in the ISA are treated as current year subscriptions if their total value is less than the lower limit.

Where an investor wants to transfer all or part of the previous year’s subscriptions, the manager should calculate the lower limit, and subtract that from the total value of the cash and investments in the ISA. Some or all the remainder can be transferred as a previous year’s subscriptions.

If the total value of the cash and other investments held in the ISA is less than the lower limit, all investments and cash held must be treated as a current year subscriptions and there are no previous years subscriptions to transfer.

Transfer applications

Investors must make a transfer application to the new ISA manager unless the ISA is being transferred into an existing ISA they hold with the new manager.

This can be achieved by asking the investor to complete:
- a transfer authority form (which is not a requirement of the ISA regulations), which the new ISA manager forwards to you and authorises you to transfer the ISA (or part of it) to them
- an ISA application form or a transfer instruction
A transfer instruction should include the appropriate authorisation to hold the ISA investments and agreement to the manager’s ISA terms and conditions — read the ISA terms and conditions in what you need from investors when they apply for an ISA (https://www.gov.uk/guidance/information-you-need-from-investors-when-they-apply-for-an-isa). It does not need to include the investor’s date of birth, National Insurance number, or any of the ISA declarations. This can be completed by someone holding a mandate for the ISA investor. Find out more about how to open an ISA as an ISA manager (https://www.gov.uk/guidance/how-to-open-an-isa-as-an-isa-manager).

To start the transfer, the investor will approach the new ISA manager.

If the new manager already holds an ISA for the investor into which the transfer will be made, a person holding a mandate to operate the account can request that the funds are moved into that account (as an application to open the account is not required). Subscriptions can be made following the transfer if the manager holds an application form that is still valid.

An application made by the investor, or someone holding a mandate for them, will be needed if:
- a new account needs to be opened
- the investor wants to subscribe to the new account
If the investor is transferring ISA savings and does not want to make any further subscriptions to the new account, the transfer can be processed by a person holding a mandate to operate the account. However, the new ISA manager cannot accept subscriptions without a new application.

The ISA application form or transfer instruction can be made by the application not in the writing process. However, you can require the transfer authority form to be signed by the investor before you release the funds. The ISA regulations do not override the requirement for a signature if one is required by your terms and conditions.

Find out more about what you need from investors when they apply for an ISA (https://www.gov.uk/guidance/information-you-need-from-investors-when-they-apply-for-an-isa).

Internal transfers

A transfer application is not required where an existing ISA investment is switched from one product to another (which is what happens on the maturity and ‘roll-over’ of a fixed-term product). The existing ISA continues (with either the same or a new account number). However, an ISA application form must be obtained where all these apply:
- the investor is eligible to subscribe to the ISA after the transfer (the residence condition is satisfied)
- the investor intends to subscribe to the ISA after the transfer
- the existing application form is no longer valid
Where one type of ISA is transferred to another type, a transfer application is required. For example, where a stocks and shares ISA is transferred to a cash ISA, and the investor intends to subscribe following the transfer.

Find out more about what you need from investors when they apply for an ISA (https://www.gov.uk/guidance/information-you-need-from-investors-when-they-apply-for-an-isa).

Cash ISA transfers

Cash ISA to Cash ISA transfers must take place within 15 business days of the transfer instruction being received by the new ISA manager, unless the investor stipulates that the 15 days starts on a later date. The 15 days are broken down as:
- The new ISA manager has 5 business days to forward the instruction to you.
- You have 5 business days to send the funds and information to be provided to the new ISA manager.
- The new ISA manager has 3 business days to apply the funds to the new ISA.
- The other 2 days are to allow for time taken for first class post between you and the new manager.
This timetable does not apply to transfers for:
- cash ISA to stocks and shares, innovative finance or Lifetime ISA
- stocks and shares, innovative finance or Lifetime ISA to cash ISA
You should complete such transfers in accordance with your ISA terms and conditions — read what you need from investors when they apply for an ISA (https://www.gov.uk/guidance/information-you-need-from-investors-when-they-apply-for-an-isa).

If the previous ISA is a notice account or a fixed-term product, the investor may incur an exit penalty or interest penalty if the funds and transfer history form are sent to the new manager within the given 5 business days.

To avoid a penalty, you can contact the investor and receive a revised instruction to transfer the ISA after:
- the notice period has expired
- the product has reached maturity
This will be treated as a new transfer instruction that initiates a fresh timetable.

Information to provide to the new ISA manager

You must give the new ISA manager a notice in writing containing information about the ISA being transferred, using a transfer history form.

The information can be given electronically and does not need a ‘wet’ signature.

Where the transfer is a bulk transfer, the information must be provided at the time of the transfer. If the investor initiates the transfer, the information must be provided within 30 days of the transfer.

If you do not send the transfer history form to the new ISA manager when transferring the ISA, you should:
- notify the new ISA manager of the type of ISA (cash, stocks and shares, innovative finance, or Lifetime ISA) and the amount transferred
- send the transfer history form to the new ISA manager within 30 calendar days from the date of transfer
Transfer history forms

You can download model ISA transfer history forms (https://www.gov.uk/government/publications/tax-on-savings-cash-isa-transfer-history-form).

You can use your own transfer history forms. However, they must contain the same information as model forms.

Complete transfer history forms as follows:

Full name

Enter the investor’s:
- forenames, or their first name and initial
- surname
Full permanent residential address

Enter the full residential address of the investor.

You must provide the investor’s current permanent address, including postcode. You can use addresses for a:
- retirement home
- nursing home
- hospice or hospital
- British Forces Post Office
‘Care of’ or other correspondence addresses are not permitted.

If you do not know the investor’s permanent residential address, you should not accept further subscriptions from them until you are given their current address.

Postcode

Enter the full postcode of the investor.

Date of birth

This should be reported in the format DDMMYYYY.

For example, the date of birth of an investor born on 3 June 1932 should be reported as xx-xxxx-xxxx.

If you only know the investor’s year of birth, report that they were born on 1 January of that year. For example, 01011932.

If the ISA is a Lifetime ISA, you must report the investor’s full date of birth.

National Insurance number

National Insurance numbers consist of:
- 2 letters
- 6 numbers
- a final letter which is always A, B, C, or D
For example, QQ123456A.

All transfer forms should contain the investors full and correct National Insurance number. You can use the ‘universal dummy National Insurance number’ (QQ999999A) if your system requires a National Insurance number and your investor:
- has not been issued with a National Insurance number but is still eligible to open an ISA
- has a National Insurance number in an old format
- has a Temporary Reference Number (TRN) — an example of the format of a TRN is 11 a1 11 11
You should not use any other dummy or substitute National Insurance number. Read the specific guidance for Junior ISAs (https://www.gov.uk/guidance/junior-isas-for-isa-managers) and Lifetime ISAs (https://www.gov.uk/guidance/lifetime-isas-for-isa-managers).

Account number

Enter the account number from your records. When transferring a Lifetime ISA, this must be the same number that was previously used to report the account to HMRC.

Type of ISA

You must enter:
- ‘A’ if all remaining current year subscriptions are being transferred
- ‘X’ if any current year subscriptions remain with you after the transfer
Enter ‘A’ if you are transferring a flexible ISA which has net current year subscriptions of £0 and a valid date of first subscription.

Date of transfer

This is usually the date when the new manager agrees to accept the transfer.

It should be reported in the format DDMMYYYY.

Amount transferred

Enter the total amount of cash being transferred.

If any investments are being transferred in specie, attach a list and tick the box.

Current year subscriptions

Only complete this box when all remaining current tax year subscriptions are being transferred (you entered ‘A’ in the type of ISA box).

Stocks and shares ISA must include any subscription made by the direct transfer of shares from a schedule 3 Save As You Earn (SAYE) option scheme, an approved profit-sharing scheme or a schedule 2 Share Incentive Plan (SIP) in the total box and also report it separately in the share scheme transfers box.

For non-flexible ISAs, enter the total amount subscribed to the ISA in the current tax year.

For flexible ISAs, you must provide the new manager with the ‘net’ subscriptions in the current year. That is, the total subscriptions in the year less any amounts withdrawn. The ‘net’ subscriptions are £0 if withdrawals are equal to or greater than the amounts subscribed.

For both flexible and non-flexible ISAs, disregard any:
- additional permitted subscriptions (https://www.gov.uk/guidance/manage-additional-permitted-subscriptions-into-an-isa)
- defaulted subscriptions, including defaulted investment subscriptions
- Help to Buy ISA reinstatement subscriptions
Find out how to manage ISA subscriptions for your investors (https://www.gov.uk/guidance/manage-isa-subscriptions-for-your-investors).

For Lifetime ISAs, include these in the notice:
- the amount of government bonus that has been paid in the current year
- the amount of government bonus that has accrued, but not yet been claimed or paid at the date of transfer
- details of any qualifying additions for which a claim has not yet been made but with separate entries in respect of a Help to Buy ISA transfer
- any other qualifying additions
Share scheme transfers

This box should only be completed when:
- the ISA is a stocks and shares ISA or a Lifetime ISA
- current tax year subscriptions are being transferred (‘A’ is entered in the type of ISA box)
- the current year subscription includes shares transferred from a schedule 3 SAYE option scheme or a schedule 2 SIP
Enter the market value of the shares on the date they were transferred into the ISA.

If the transfer is from a stocks and shares ISA to a cash ISA, the receiving cash ISA manager can ignore the entries made here as they do not need to include the details on their annual ISA return.

Date of first subscription in current year

This box should only be completed if all remaining current tax year subscriptions are being transferred (you entered ‘A’ in the type of ISA box).

Enter the date on which the first subscription was made in the tax year of transfer. It should be reported in the format DDMMYYYY.

Use the Bacs (Bankers Automated Clearing System) default date of first subscription (6 April) if:
- the net current year subscriptions are £0
- you cannot override the Bacs default date
For flexible ISAs, use the date of the first current year subscription that counts towards the subscription limit. The replacement of an amount withdrawn earlier in the current year does not count towards the limit.

Disregard any:
- additional permitted subscriptions (https://www.gov.uk/guidance/manage-additional-permitted-subscriptions-into-an-isa)
- defaulted subscriptions including defaulted investment subscriptions
- Help to Buy ISA reinstatement subscriptions
Find out how to manage ISA subscriptions for your investors (https://www.gov.uk/guidance/manage-isa-subscriptions-for-your-investors).

Date on which the Lifetime ISA was opened

If the account transferred is a Lifetime ISA, the form must also give the date when it was first opened. If the Lifetime ISA was opened to receive either defaulted Lifetime ISA subscriptions or a returned withdrawal following a failed first time residential purchase, then the date when it was first opened will be the same as the Lifetime ISA where the original payment came from.

Withdrawal for a first-time residential purchase

If the account is a Lifetime ISA, the notice must confirm if there has been a withdrawal for a first-time residential purchase.

It must also confirm if any of the information required from the conveyancer declaration is not currently available. If so, it must also contain an undertaking to pass the information onto the new ISA manager as soon as possible.

Read ‘Lifetime ISAs for ISA managers (https://www.gov.uk/guidance/lifetime-isas-for-isa-managers)’.

Date of Transfer

You and the new ISA manager must agree a common transfer date. Unless otherwise agreed, this will be either:
- the date in the ‘transfer acceptance’ section of the ISA transfer authority form
- the date of the investor’s transfer instruction form
The transfer date establishes:
- the date from which the new ISA manager can accept subscriptions
- which manager is responsible for including details of the transferred ISA in their Lifetime ISA claims and ISA annual returns
The new ISA manager can accept subscriptions from the date of transfer if they hold a valid ISA application form.

If an ISA transfer straddles the end of a tax year, the ISA is included in:
- the new manager’s annual returns if the transfer date is 5 April (or earlier)
- your annual returns if the transfer date is 6 April (or later)
Income you receive after the date of transfer

You should send any income you receive after this date to the new ISA manager unless either:
- you have been instructed to pay the income you receive to the investor
- the income you receive is less than the minimum amount that the new manager will accept
If the receipt includes a government bonus for a Lifetime ISA, you must forward this directly to the new ISA manager. If you do not do this, a withdrawal charge may be due.

Information to be provided to the transferring manager by the new manager

If the account to be transferred is a Lifetime ISA, the new manager must tell you which type of ISA the account is being transferred to.

If the new account is not a Lifetime ISA, the transferred amounts will be treated as withdrawn from the Lifetime ISA. A withdrawal charge may be due, and you should deduct this before transferring the funds to the new manager.

Bulk transfers

A bulk transfer takes place when either:
- 2 managers agree to transfer 2 or more accounts between them without the agreement of the account investors, for example where an ISA manager has decided to rationalise or reorganise their ISA book by selling some or all of it to another manager
- the transfer takes place under an insurance business transfer scheme or a banking business transfer scheme under part 7 of the Financial Services and Markets Act 2000 (FSMA)
Before making a bulk transfer, you must notify HMRC and your investors whose accounts are being transferred. Your notice must:
- give the first day on which accounts will be transferred under the bulk transfer
- be provided at least 30 days before the bulk transfer
- provide the name and address of the manager who will receive the accounts
In addition, your notice to investors must:
- identify the account being transferred
- advise that the investor can arrange a transfer to a manager of their choice if they supply instructions by a certain date
- specify the date for receiving those instructions
- state that if the investor opts out of the bulk transfer but does not provide further instructions in time, they will lose their ISA status (except for Junior ISA) — in the case of a Lifetime ISA, this will be treated as a withdrawal and may be liable to a withdrawal charge
If you will stop offering ISAs after the bulk transfer, you must make your final returns so your HMRC record can be closed.

Find out about ceasing to be a manager (https://www.gov.uk/guidance/apply-to-be-an-isa-manager).

When making a bulk transfer, you do not need to complete separate transfer history forms for each ISA being transferred. Instead, you can give the new manager a schedule containing the information that would normally be entered on the transfer history forms.

Alongside the schedule, you must also send a covering notice to the new ISA manager. This notice should identify the ISAs being transferred by referring to the accompanying schedule.

If the transfer takes place to an existing account held with the new manager, the investor can make further subscriptions to the account if the application form held by the new manager for that account is still valid. Read what you need from investors when they apply for an ISA (https://www.gov.uk/guidance/information-you-need-from-investors-when-they-apply-for-an-isa).

If the transfer is made to a new account, the new ISA manager can only accept subscriptions to that account if an application form has been given to the new manager and that application is valid.

If the investor made subscriptions to you by direct debit, the new manager cannot use that direct debit to collect payments until they hold a valid application form. They can accept the money provisionally, but if they do not receive a completed application form within 30 days, they must:
- void the subscription
- remove investments purchased with the subscription from the ISA
Alternatively, the manager can put the money in a suspense account until they receive a fully completed application.

Group Transfers

A ‘group transfer of accounts’ is a bulk transfer that takes place between members of a 75% group of companies. For example, this could be when:
- one of the companies is a 75% subsidiary of the other
- both companies are 75% subsidiaries of a third company
Following a group transfer or a bulk transfer of accounts under Part 7 of FSMA, the new manager can accept subscriptions to the account if:
- the most recent application held by you is available to them
- the application to subscribe to an ISA is still ‘valid’
The application is available to the new manager if:
- you have passed it (or a copy) to them
- they could require you to make it available to them
An intra-group transfer can include cases where the new manager has accepted an application (usually online) but is still waiting for the first subscription. If the application is available and still valid, they do not need to get a fresh one.

Subscribing to the ISA after the transfer

If the investor wants to subscribe to the ISA after the transfer, the new ISA manager must get an ISA application form, unless they already have a valid transfer application form.

In that case the application form would be valid for subscriptions made in:
- the year of transfer
- each successive year following the year of transfer, in which the applicant subscribes to the ISA
Other than for a Lifetime ISA, the application would stop being valid at the end of a tax year in which the investor does not make a subscription, depending on the terms and conditions of the account and the investors instructions on the transfer application. Read what you need from investors when they apply for an ISA (https://www.gov.uk/guidance/information-you-need-from-investors-when-they-apply-for-an-isa).

Sometimes, an ISA manager can accept an application signed by someone other than the investor. Read how to open an ISA as an ISA manager (https://www.gov.uk/guidance/how-to-open-an-isa-as-an-isa-manager).

Reporting subscriptions made in the year of transfer

Full transfers

A full transfer is the complete transfer of all current year subscriptions (as a single or multiple transaction) or a transfer of all the ISA subscriptions, which subsequently closes the account. The old manager must exclude the subscriptions from their annual return of information and should include current year subscription information on the transfer history form. The new manager must include the subscriptions on their annual return of information.

Partial transfers

A partial transfer is the transfer of part of the current or previous year subscriptions, where the originating account is not closed. If part of the current year subscriptions remains with the old manager, they should report all current year subscriptions they received from the investor on the annual return of information. The new manager should report all current year subscriptions they receive from the investor after the transfer date. For partial transfers, there is no requirement for the old manager to provide details of current year subscriptions to the new manager. If no details of current year subscriptions are provided on the transfer history form then partial transfers of current year subscription should be reported as ‘X’ on the transfer history form.

Find out more about reporting for annual returns of information (https://www.gov.uk/guidance/returns-of-information-for-isa-managers) and annual returns of statistical information (https://www.gov.uk/guidance/annual-returns-of-isa-statistical-information-to-hmrc).

Do not report information about Lifetime ISAs you hold in your annual information return (ISAComm100). This is currently reported to HMRC within 60 days of the end of the tax year.

Information about Lifetime ISAs should now be reported in a digital format, specified by HMRC. Read digital reporting for Lifetime ISAs (https://www.gov.uk/guidance/digital-reporting-for-lifetime-isas).

Claims for payment of tax on income paid after the transfer date

As the old manager, you cannot normally make claims for the payment of tax on income received on or after the date of transfer.

However, you may agree with the new manager that you can claim payment of tax on such income for up to 6 months after the date of transfer.

You should send the income received (and tax claimed) to the investor if either:
- your instructions were to pay any income to the investor
- the amount is less than the minimum the new manager will accept
Otherwise, you should forward the income (and tax reclaimed) to the new manager.

If you receive income for a Lifetime ISA, and it is not paid into the Lifetime ISA:
- it will be treated as withdrawn from the Lifetime ISA
- there may be a withdrawal charge, which you should deduct before paying the income to the investor
If you have not made, and do not intend to make, a claim for income you received either:
- up to and including the date of transfer
- from the date of transfer
The new manager can make the claim. You should forward the relevant tax vouchers to the new manager.

Cancellation of a transfer

Under Financial Conduct Authority (FCA) rules, when transferring an ISA to a new contract, the new manager may need to offer the investor the option of either:
- cancellation rights
- pre-contractual withdrawal rights (cooling off)
The time periods offered by the manager are determined by:
- the type of ISA being transferred into
- whether the contract is a distance or non-distance (retail) contract
- whether the ISA manager has chosen to offer withdrawal rights rather than cancellation rights
- whether the ISA includes an insurance policy
- whether the manager chooses to voluntarily offer a longer cancellation period than that stipulated in the FCA sourcebook (there are further details on the treatment of tax liability if the cancellation period does not exceed 30 days)
Cancellation periods offered are typically between 14 and 30 days and withdrawal periods will be either 7 or 14 days.

If the new ISA manager offers a 7 or 14 day withdrawal period, they should not forward the transfer request to you until this period ends. The investor has 7 or 14 days (the withdrawal period) to reconsider their decision to transfer. If, during this time, they inform the new manager that they do not want to proceed with the transfer, the new manager should not progress it any further. They will not forward the transfer request to you, and the funds will stay in the original ISA under your management.

If the new manager does not offer a withdrawal period, there is a 14 to 30 day cancellation right. The ISA will be transferred to the new manager before the 14 to 30 day cancellation period begins. If the investor decides to cancel, the purchase of the investment in the new ISA is cancelled but not the transfer itself. The investor has an ISA with the new manager. The investor can do any of these:
- invest the money in a different investment offered by the new ISA manager (for Lifetime ISAs that the account remained within a Lifetime ISA wrapper)
- close the ISA (for Lifetime ISAs, this is treated as a withdrawal so will be subject to a withdrawal charge, which must be deducted before closing the ISA)
- transfer the ISA back to you (for a Lifetime ISA, it must remain within a Lifetime ISA wrapper or be subject to a withdrawal charge, which must be deducted before the transfer)
- transfer the ISA to another ISA manager (for a Lifetime ISA, it must remain within a Lifetime ISA wrapper or be subject to a withdrawal charge, which must be deducted before the transfer)
Read ‘Lifetime ISAs for ISA managers (https://www.gov.uk/guidance/lifetime-isas-for-isa-managers)’ to find out more about closing a Lifetime ISA.

Transfers-in that cannot be accepted by the new ISA manager

Sometimes, the new ISA manager may be unable to accept an incoming transfer. This is usually because:
- they realise that the amount of current year subscriptions being transferred exceed the annual subscription limit (or Lifetime ISA payment limit) when added to the amount already subscribed with them in the current year
- it arrives after the date by which all transfer proceeds must be received for a structured product (or similar) on sale only for a limited time
- they realise that the terms and conditions of the ISA product do not allow transfers-in
If accepting a transfer of current year subscriptions would exceed the annual subscription limit, the new manager can either:
- remove the excess current year subscriptions, pay them to the investor, and pay the balance into the ISA
- return the current year subscriptions to you, with a note explaining why they cannot accept them
If the new manager removes the excess current year subscriptions, pays them to the investor, and pays the balance into the ISA they can ignore any growth on the amount removed, however, this does not apply in respect of Lifetime ISAs. If the investor claims that the value of the excess subscription is less than the amount originally subscribed, the new manager will need to contact you to determine the value. If this is less than the amount subscribed only the value needs to be removed.

In all other circumstances, the new manager should return the cheque to you, with a note explaining why they cannot accept it.

This could leave the transfer ‘in limbo’ because:
- you, as the old manager, have followed the instructions to transfer-out
- a transfer-out has happened under the ISA regulations
- the new manager has not processed the transfer-in
In this scenario, you must reinstate the ISA if it is a Lifetime ISA. You should reinstate other types of ISAs if you are able to do so. This would put the investor back in the position they would have been in had the transfer-out not happened.

If you cannot reinstate the old ISA, you can allow the investor to put the returned or rejected proceeds into another of your ISA products. For example, if the old product is a fixed-rate product that cannot be reopened after closure.

You should treat this as an internal transfer between ISA products, otherwise the sum is a subscription and is subject to the ISA subscription limits. If the old ISA is a Lifetime ISA, and the proceeds are not placed in a Lifetime ISA, this is a withdrawal from a Lifetime ISA and a withdrawal charge may apply. You should deduct any withdrawal charges from the proceeds.

You do not have to reinstate an ISA, unless it is a Lifetime ISA. If you do not want to reinstate the ISA, you should allow the investor to transfer it to another provider, so the ISA status of the savings is not lost.

Cash withdrawn in error as a result of incorrect transfer advice by an ISA manager

If you or the new manager give incorrect advice about a transfer application, and this leads to cash being withdrawn from an ISA in error (https://www.gov.uk/guidance/how-to-manage-an-isa-investment-fund), HMRC may allow reinstatement if there is clear evidence that:
- the investor intended to transfer the ISA
- incorrect advice was given to them by an ISA manager
Flexible ISA transfers

Where a Flexible ISA is transferred, you must provide the new manager with:
- the ‘net’ subscriptions in the current year, which is the total subscriptions in the year less any amounts withdrawn (disregarding any additional permitted subscriptions (https://www.gov.uk/guidance/manage-additional-permitted-subscriptions-into-an-isa),defaulted subscriptions and Help to Buy ISA reinstatement subscriptions (https://www.gov.uk/guidance/manage-isa-subscriptions-for-your-investors) — if withdrawals equal or exceed the amounts subscribed, provide a £0 figure
- the date of the first subscription in the current year that counts towards the subscription limit, which is the date of the first subscription that is not a replacement of amounts previously withdrawn in the year — additional permitted subscriptions and defaulted subscriptions should be ignored for this purpose
Use the Bacs default date of first subscription (6 April) if both:
- the net year current subscriptions are £0
- you cannot override the Bacs default date