From April 2027, SIPP funds are brought into IHT without grandfathering. Money paid in under terms that were not subject to IHT on death will now be counted in the estate.

The scheme terms were documented. The IHT arrangement (the deal terms) was not fixed by contract, and no disclosure warned that Parliament could change it at will. If that was always the arrangement — call it the undisclosed risk scenario — savers were not sufficiently informed about a material risk in what they were buying. That is a mis-selling argument. If it wasn’t — if savers were entitled to treat the IHT terms as part of the deal, call it the fixed deal scenario — then changing them now is a breach of what they were sold.

Under the fixed deal scenario, the straightforward resolution would have been to close the old deal to new contributions and open a new one under explicit terms. Existing funds continue under the rules they were committed under; new contributions are made under the new terms. Providers run two account types for a time. That is unremarkable. The problem is not that the law changed — it is that the change was applied to capital already committed under a different deal.

“Because it’s the government” isn’t a satisfying resolution. It’s just an answer about who has the power to avoid the question.