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1. Changes to regulations 

The Individual Savings Account and Child Trust Fund Regulations were laid before Parliament on 24 June 2025. These make several changes to the Individual Savings Account Regulations, which come into effect from 15 July 2025.

1.1 European Economic Area Undertakings for Collective Investment in Transferable Securities and the Overseas Funds Regime

To qualify for an Individual Savings Account or Child Trust Fund, European Economic Area Undertakings for Collective Investment in Transferable Securities must be recognised schemes under Financial ÌìÃÀÓ°Ôº and Markets Act 2000. Funds in the Temporary Marketing Permissions Regime meet this requirement, as do funds in the Overseas Funds Regime.

The Financial Conduct Authority began a transition from the Temporary Marketing Permissions Regime to the Overseas Funds Regime on 1 October 2024 which runs until 31 December 2026. This change accommodates an orderly transition of recognised funds, which are qualifying investments for Individual Savings Accounts and Child Trust Funds in the Temporary Marketing Permissions Regime and Overseas Funds Regime from 1 October 2024 to 31 December 2026. Funds which were recognised under the Temporary Marketing Permissions Regime on 1 October 2024 will remain as Individual Savings Account and Child Trust Fund qualifying investments until 31 December 2026. This includes new and existing investments in those funds, and any new funds created within an existing recognised umbrella fund.

From 1 January 2027, only recognised funds in the Overseas Funds Regime  will be Individual Savings Account and Child Trust Fund qualifying investments. Any funds that are not recognised, including those held pre EU-exit, will be non-qualifying.

1.2 Long-Term Asset Funds

This change includes a definition for Long-Term Asset Funds in the Individual Savings Account regulations and clarifies that authorised Long-Term Asset Funds are qualifying investments for an innovative finance Individual Savings Account.

1.3 Flexible Individual Savings Account

This change clarifies that funds subscribed in a tax year which are subsequently withdrawn from a flexible account, should reduce the total value of current year subscriptions to the account, and may be subscribed to any other Individual Savings Account in that same year. An amount withdrawn that exceeds current year subscriptions, is considered a withdrawal of previous year subscriptions and can only be replaced as a replacement subscription to the same account.

1.4 National Insurance number

From 6 April 2027, subscriptions may only be made to an Individual Savings Account where the National Insurance number has been provided, unless the investor has declared that they are not eligible for one. This change will apply to new and existing Individual Savings Account accounts.

2. Individual Savings Account managers guidance updates

We will be updating the Individual Savings Account managers guidance to reflect updates to the Individual Savings Account Regulations which come into force on 15 July 2025. 

Information you need from investors when they apply for an ISA and How to manage ISA subscriptions  will be updated to include the requirement for a National Insurance number for any account receiving a subscription from 6 April 2027, unless the investor has declared that they are not eligible for one.

How to manage ISA subscriptions will be updated to clarify the position on flexible Individual Savings Account withdrawals of current year subscriptions.

Applications for ISA manager status and Child Trust Fund guidance notes for providers will be updated to include that any recognised fund that was recognised under the Temporary Marketing Permissions Regime on 1 October 2024, will continue to be treated as a recognised fund until the end of the transition period on 31 December 2026, and that from 1 January 2027, only recognised funds will qualify for inclusion.

3. Investor queries

As an Individual Savings Account manager, you should aim to resolve your investor’s queries in line with the Individual Savings Account Regulations and guidance. Where you are unable to resolve the query, you can contact HMRC for advice at savings.audit@hmrc.gov.uk quoting the relevant legislation, guidance and investor issue.

4. Individual Savings Account applications

Individual Savings Account applications do not need to be kept beyond 6 years after the account is opened. Find more information on keeping records.