ISA additional permitted subscription: inheriting your spouse's or civil partner's ISA allowance

If your spouse or civil partner lived with you and died, you can pay in up to their ISA value on top of your own allowance. Who qualifies, time limits.

The short answer

If your husband, wife or civil partner died on or after 3 December 2014 holding ISAs, you can pay extra into your own ISA up to the value of theirs, on top of your normal £20,000 allowance for 2026/27. This is the additional permitted subscription (APS). GOV.UK puts it as inheriting their ISA allowance: "As well as your normal ISA allowance you can add a tax-free amount up to either the value they held in their ISA when they died [or] the value of their ISA when it's closed" (GOV.UK: inheriting an ISA from your spouse or civil partner).

The rule is in regulation 5DDA of the Individual Savings Account Regulations 1998 (SI 1998/1870), and regulation 5D(1) says a subscription made under it "must be disregarded" for the annual subscription limit in regulation 4ZA(1). It does not move money out of the deceased's ISA: it is extra room in yours. You can fill it with money you inherit or with any other cash of your own (HMRC: how to manage additional permitted subscriptions).

Who qualifies

  • Married or in a civil partnership. Regulation 5DDA(2)(a) covers an account investor who dies on or after 3 December 2014 "leaving a surviving spouse or civil partner". Unmarried partners who lived together are not covered. GOV.UK: "You cannot inherit someone's ISA allowance if they died before 3 December 2014."
  • Living together at the date of death. Regulation 5DDA(2)(d) requires it, and the declaration in regulation 5DFA(2)(b) applies the test in Income Tax Act 2007 s.1011: a married couple or civil partners are treated as living together unless "separated under an order of a court of competent jurisdiction", "separated by deed of separation", or "in fact separated in circumstances in which the separation is likely to be permanent".
  • You do not need to have inherited the ISA. HMRC's manager guidance says the APS is available "whether or not the surviving spouse or civil partner inherited the deceased's ISA assets", and that it "can be made by non-residents" (HMRC APS guidance). Paying into a Lifetime ISA has extra conditions, below.

How much: date of death or closure value

For deaths on or after 6 April 2018, an ISA does not close on death. Under regulation 2G it becomes a continuing account of a deceased investor, and its investments stay inside the ISA wrapper until the earliest of: completion of the administration of the estate, the third anniversary of the death, or the day all the investments and cash are withdrawn. No new money can be paid into it (regulation 2G(4)). GOV.UK says the provider will otherwise close it "3 years and 1 day after you die" (GOV.UK: ISAs if you die).

The APS limit under regulation 5DDA(3) is the value of the deceased's ISAs with one provider either at the date of death or immediately before the account stopped being a continuing account, "whichever is the higher". There is a catch: the closure value is available only if you have not already paid in under the date-of-death figure. HMRC: once you subscribe using the date-of-death value, you "cannot then ask" for the value at closure (HMRC APS guidance).

  • More than one ISA with the same provider: the limit is their combined value, all at the date of death or all at closure. HMRC says you cannot mix the two dates within one provider.
  • ISAs with different providers: you get a separate limit with each, and can choose date of death with one and closure with another.
  • Junior ISAs are excluded: regulation 5DDA(3) "does not include any sums the deceased held in a junior ISA account", and you cannot pay the APS into a Junior ISA.
  • A Lifetime ISA counts, including any government bonus accrued but not yet paid (regulation 5DDA(3B)).
  • Deaths from 3 December 2014 to 5 April 2018: the ISA ended on the date of death and the APS is the value held then (GOV.UK). For deaths from 3 December 2014 to 5 April 2015, the death is treated as happening on 6 April 2015 for the cash time limit (regulation 5DDA(5)(b)), so cash could be paid in until 5 April 2018 or, if later, 180 days after the estate was completed (regulation 5DFA(3)(b)).

Time limits

Regulation 5DDA(4) sets two "permitted periods":

  • Cash: from the date of death until 3 years after it, or until 180 days after the administration of the estate is complete, "whichever is the later".
  • Inherited investments (in specie): within 180 days of the estate distributing them to you. HMRC says each interim and final distribution gets its own 180-day window, and treats the start as the date the provider is formally told the assets belong to you.

You can pay in one go or in several payments up to the limit, but whether a provider accepts more than one APS payment is up to its terms. HMRC tells providers that accept only one to make clear "that any unused balance will be 'lost'" (HMRC APS guidance).

Which provider, and cash or in specie

  • No provider has to accept it. HMRC: "ISA managers are not obliged to accept additional permitted subscriptions." You can use the provider that held the deceased's ISA or "another manager who agrees to accept the subscriptions".
  • One provider per limit. Regulation 5DDA(2)(b) requires the subscription to go to accounts managed by a single provider. HMRC: once an APS is made, further payments up to the limit "must be made with the same manager", and an unused balance cannot be used with another.
  • Using a different provider. You give it the deceased's details and declarations (regulations 5DF and 5DFA). It sends a notice to the deceased's provider within 30 days, and that provider has 30 days to reply with the APS value (regulation 5DFB). HMRC says the 30 days can be suspended until a death certificate is received.
  • In specie (without selling): normally only with the deceased's provider (regulation 5DDA(2)(b)), and only for investments the deceased held in the ISA at the date of death that you inherit, where title stayed with that provider, its nominee or jointly with one of them throughout, from the day the provider was told of the death until you subscribe (regulation 5DDA(2)(e)(i), (ii) and (iv)). They count at their value on the day you subscribe. Otherwise the APS must be paid in cash. The exception: HMRC can authorise another provider to accept it (regulation 5DDA(6)), and HMRC's guidance says that after a bulk transfer of ISAs, in specie subscriptions can go to the receiving provider or to a new provider you choose.
  • Account types: cash, stocks and shares and innovative finance ISAs, new or existing. Not a Junior ISA. Except in a Lifetime ISA, an APS counts as previous years' subscriptions for other ISA purposes, so you can transfer it later under the normal rules. See the types of ISA and how the annual ISA allowance works.

Lifetime ISA and Junior ISA

An APS can go into a Lifetime ISA, but unlike other ISAs it does count towards the Lifetime ISA payment limit of £4,000 a year (regulation 4ZA(1A)). HMRC's guidance says a provider must not accept it if you are 50 or over, are not UK resident, have already paid into another Lifetime ISA that tax year, or the payment would take you over the limit; and a new Lifetime ISA cannot be opened for it if you are 40 or over (HMRC APS guidance). In practice most of a large APS will go into other ISA types. More in our Lifetime ISA guide.

If the person who died held a Lifetime ISA, its value counts towards your APS and includes bonus accrued on payments made on or before the date of death. HMRC says the estate receives that bonus only once the Lifetime ISA is closed (HMRC: Lifetime ISA when an investor dies). A Junior ISA the deceased held is not part of the APS, and an APS cannot be paid into a Junior ISA.

Illustrative example

Illustrative figures, not anyone's real case. A married couple live together. One dies holding a stocks and shares ISA worth £40,000 with Provider A, and has left everything to their children, not to the surviving spouse.

  • The ISA becomes a continuing account. Income and gains in it stay free of Income Tax and Capital Gains Tax while the estate is administered.
  • The executors finish administering the estate 14 months after the death, when the account is worth £44,000, and it stops being a continuing account.
  • The surviving spouse has not paid in any APS yet, so their limit with Provider A is the higher figure, £44,000. Not having inherited the ISA does not matter: they can use their own savings.
  • They can also pay their normal £20,000 for 2026/27 into any ISA, a total of £64,000 that tax year if they had the cash.
  • The cash deadline is the later of 3 years after the death and 180 days after the estate was completed (about 20 months after the death), so here it is 3 years after the death.

If they had paid in any APS before the account closed, they would have fixed the limit at the date-of-death value, £40,000. If Provider A did not accept APS payments, they would need another provider willing to.

Inheritance Tax: the APS changes nothing

The APS protects future income and gains from Income Tax and Capital Gains Tax. It is not an Inheritance Tax relief. GOV.UK: "ISA investments will form part of your estate for Inheritance Tax purposes" (GOV.UK: ISAs if you die). Whether any Inheritance Tax is due depends on who inherits: GOV.UK says there is normally none to pay on what you leave to a spouse or civil partner (GOV.UK: Inheritance Tax). That is the spouse exemption in IHTA 1984 s.18, which has a cap where the person who died was a long-term UK resident and their spouse is not. ISAs left to anyone else count towards the estate in the usual way: try the Inheritance Tax calculator.

The Income Tax exemption for income during the continuing-account period comes from ITTOIA 2005 s.694A (administration-period investments), with regulation 2G setting how long that period lasts. For gains, GOV.UK says there is no Capital Gains Tax to pay until the ISA ends (GOV.UK). HMRC says interest, dividends and gains that arise after the death and before the ISA closes are exempt (HMRC: death of an investor).

Your own allowance alongside the APS

Your normal allowance for 2026/27 is £20,000 (regulation 4ZA(1)), and the APS sits on top of it. See our ISA allowance guide for how the allowance works.

Cash ISA limit from April 2027. Regulations already made (SI 2026/1018) add a £12,000 cash ISA limit from 6 April 2027 for anyone aged 64 or under at the end of the tax year (new regulation 4ZA(1ZA)). Those regulations do not amend regulation 5D, so they do not say how an APS paid in cash interacts with the new cash limit. Budget 2026 (28 October 2026) announced that the government "will retain the cash ISA limit at £20,000 for all savers over 18 years old from April 2027", by secondary legislation it said would be laid in November 2026 (Budget 2026 OOTLAR section 2.5). When this page was checked on 30 October 2026 those reversing regulations had not been made, so the £12,000 limit was still the law as it stood, with its reversal announced.

For everything else to sort out after a death (registering it, benefits, the estate), see the financial steps after a bereavement. If you were under State Pension age when your spouse or civil partner died, check the Bereavement Support Payment calculator.

Frequently asked questions

What is an ISA additional permitted subscription?

An extra ISA allowance for a surviving spouse or civil partner who was living with the deceased when they died, on or after 3 December 2014, holding ISAs. You can pay in up to the value of their ISAs on top of your own £20,000 for 2026/27. Under regulations 5DDA and 5D of the ISA Regulations 1998 it is ignored for the £20,000 overall limit, but HMRC says it counts towards the £4,000 Lifetime ISA limit if paid into one.

How much is the additional permitted subscription?

For deaths on or after 6 April 2018 it is the value of the ISAs the deceased held with that provider, either at the date of death or when the account stopped being a continuing account of a deceased investor. You get the higher of the two only if you have not already paid in using the date-of-death figure. Junior ISA money is excluded. For deaths from 3 December 2014 to 5 April 2018 it is the value at the date of death.

Who can use an ISA additional permitted subscription?

Only a surviving spouse or civil partner who was living with the deceased at the date of death. Under Income Tax Act 2007 s.1011 you count as living together unless separated by court order, by deed of separation, or in fact in circumstances likely to be permanent. Unmarried partners do not qualify. You can use it whether or not you inherited the ISA, and non-UK residents can use it, except by paying into a Lifetime ISA.

What is the time limit for an additional permitted subscription?

Cash can be paid in from the date of death until 3 years after it, or until 180 days after the administration of the estate is complete if that is later. Inherited investments transferred in specie must be paid in within 180 days of being distributed to you by the estate.

Does my ISA provider have to accept an additional permitted subscription?

No. HMRC's guidance for ISA managers says they are not obliged to accept them. You can use either the provider that held the deceased's ISA or another provider that agrees. Once you have paid some in with one provider, the rest of that limit must go to the same provider. In specie transfers are only possible with the deceased's provider.

Does the additional permitted subscription affect Inheritance Tax?

No. It is an Income Tax and Capital Gains Tax allowance, not an Inheritance Tax relief. GOV.UK says ISA investments form part of the deceased's estate for Inheritance Tax. What is left to a spouse or civil partner is usually exempt under IHTA 1984 s.18, which has a cap where only the person who died was a long-term UK resident.

Use this calculator

Copy a citation linking back to this page. Attribution required under CC BY 4.0.

Plain text
 
HTML
 
Markdown
 

Paste an iframe into your blog or page. Free for any use; the embed shows a small "Powered by salarytax.uk" link.

Basic embed
<iframe
  src="https://salarytax.uk/embed/salary-calculator"
  width="100%"
  height="920"
  frameborder="0"
  loading="lazy"
  title="UK Salary Calculator by SalaryTax"
  style="border: 1px solid #e0e0e0; border-radius: 4px;"
></iframe>
Compact embed
<iframe
  src="https://salarytax.uk/embed/salary-calculator-compact"
  width="100%"
  height="380"
  frameborder="0"
  loading="lazy"
  title="UK Salary Calculator (compact) by SalaryTax"
  style="border: 1px solid #e0e0e0; border-radius: 4px; max-width: 560px;"
></iframe>

Full embed docs and live preview →