On 13 July 2026, often referred to in tax circles as Legislation Day or L-Day, the government published a substantial package of draft legislation destined for the Finance Bill 2026-27. The measures touch on a strikingly broad sweep of the tax system, from cryptoassets and pensions to HMRC’s information-gathering powers, and most were first trailed at the Autumn Budget 2025 or set out in more detail as part of Tax Update 2026 earlier this year.
The purpose of L-Day is to give the draft clauses an airing before they are formally introduced to Parliament. The legislation has been released for technical consultation, accompanied by explanatory notes, policy papers and, in several cases, summaries of earlier consultation responses. This gives accountants, tax advisers, businesses and representative bodies the chance to scrutinise the drafting and flag anything that might not work as intended before the Bill itself is laid before the Commons, typically following the Autumn Budget. The technical consultation on this year’s package closes on 7 September 2026, with a couple of additional consultations, including one on the tax treatment of predevelopment costs, remaining open into October.
Cryptoassets brought further into the mainstream tax regime
Among the more eye-catching measures is a change to how stablecoins are treated for tax purposes. From April 2027, eligible stablecoins will be treated more like money than like a typical cryptoasset. For individuals, this means returns on stablecoins will fall within the income tax regime rather than being taxed as capital gains. A related change will treat certain disposals involving cryptoasset loans and liquidity pools as “no gain, no loss” for capital gains tax purposes, effectively deferring any CGT liability until the underlying cryptoasset is genuinely disposed of on an economic basis. Together, the two measures signal a government keen to modernise the tax treatment of digital assets rather than continue applying rules designed for more conventional investments.
Pensions, savings and employee incentives
Several provisions affect how people save and how employers reward staff. Defined benefit pension schemes will, from April 2027, be permitted to make authorised surplus payments to members, a change long sought by the pensions industry as a way of sharing scheme surpluses more flexibly. Employers offering Enterprise Management Incentive options will also see red tape removed, with the requirement to notify HMRC of new EMI grants abolished for options granted from April 2027. Looking further ahead, an ISA compliance framework designed to support digital reporting is due to take effect from April 2028, intended to keep the ISA system operating as originally intended as more providers move to digital administration.
Business, international and administrative reforms
The package also confirms a series of business tax reforms. The government intends to introduce the “pillar two side-by-side” package affecting the multinational top-up tax and domestic top-up tax regimes, alongside further amendments to those rules for accounting periods beginning on or after 31 December 2026. Once the energy profits levy comes to an end, expected in March 2030, it will be replaced by a new permanent oil and gas revenue levy. There are also plans to modernise the stamp taxes on shares framework from 2027, and to introduce an electric vehicle excise duty from April 2028, building on a consultation document published earlier this year.
On the administrative side, HMRC’s civil information and inspection powers are being modernised, including updated definitions relating to computer records, effective from Royal Assent of the Finance Bill 2026-27. A new collection mechanism will also be introduced so that informants receiving a reward under the Strengthened Reward Scheme have income tax deducted at source at the additional rate of 45%, again from Royal Assent. Separately, reforms to how benefits in kind are reported and taxed continue to move forward, building on the wider push towards mandatory payrolling of benefits in kind. A further consultation proposes aligning the time limits for recovering National Insurance contributions with those for income tax, closing on 12 October 2026.
Higher education providers have not escaped attention either, with a new annual international student levy proposed from August 2028, while businesses with foreign permanent establishments face reform of how those establishments are taxed, alongside explicit rules treating exploration and exploitation rights connected to UK or UK continental shelf activities as immovable property for tax purposes.
Industry response
Professional bodies have moved quickly to digest the package. ICAEW’s Tax Faculty has confirmed it will be responding formally to the technical consultation and to the related consultations announced alongside it, and has invited members to submit feedback by 7 August 2026 so it can be reflected in the Institute’s representations. That pattern is typical of the reaction from the wider tax profession each year: broad support for the principle of consulting on draft clauses before they become law, paired with detailed scrutiny of individual measures, particularly where new administrative burdens fall on businesses or where transitional arrangements need to be got right. Given the scale of change already flowing from Autumn Budget 2025, including reforms to inheritance tax reliefs and other measures working their way through Finance Act 2026, advisers are likely to focus much of their attention on ensuring this next wave of legislation avoids similar controversy.
What happens next
With the consultation period running until early September, and the predevelopment costs and National Insurance time limit consultations open a little longer, the coming months will see close engagement between HMRC, HM Treasury and the tax profession. The government will then refine the clauses in light of that feedback before the Finance Bill 2026-27 is formally introduced to Parliament, most likely in the period following the next Autumn Budget. Anyone affected by the measures summarised here, particularly those holding cryptoassets, running defined benefit pension schemes, or operating internationally, would be well advised to review the draft clauses and supporting documents on the government’s Finance Bill 2026-27 collection page while there is still time to influence the final wording.
