BuyMeWhiskey
🇬🇧 UK

How does an inherited ISA APS work, and how should I choose a provider?

Looking for US rules? → US IRA & Roth IRA limits

UKPublished · Written by BuyMeWhiskey Editorial Team · How we check facts

A surviving spouse or civil partner can receive an Additional Permitted Subscription based on a deceased ISA, on top of the ordinary ISA allowance. The APS is separate from inheriting the ISA itself, and the chosen provider must agree to accept it.

Get the deceased ISA valuation and contact potential providers about their APS acceptance, deadlines, fees and transfer process before moving inherited assets.

Read HMRC APS guidance

An inherited ISA and an Additional Permitted Subscription (APS) are related, but they are not the same account or allowance

When an ISA holder dies, the surviving spouse or civil partner can receive an Additional Permitted Subscription allowance on top of the normal annual ISA subscription limit. HMRC says the APS is available even if the survivor did not inherit the deceased person’s ISA assets. The value of the APS is linked to the deceased ISA under the rules, while the inherited ISA itself remains part of the estate and has its own administration.

The APS can generally be made to the deceased person’s existing ISA manager or another manager willing to accept it. HMRC also says the manager is not obliged to accept APS subscriptions, so provider choice matters before money is moved. A survivor can use the allowance for cash, stocks-and-shares or other permitted ISA types subject to the specific rules.

The amount is based on the deceased ISA, not simply the survivor’s annual allowance

For a single deceased investor’s ISA, the APS calculation can be based on the ISA value at the relevant date under the regulations. Where there are multiple ISAs, HMRC has specific rules for combining values and using the appropriate valuation date. Do not assume that the amount equals whatever cash happens to be left in one account months after death.

There are deadlines

For cash APS subscriptions, HMRC’s guidance provides a three-year period from death, or 180 days after the administration of the estate is complete if later. Non-cash inherited assets have additional timing and ownership rules. The practical step is to contact the chosen ISA manager early and obtain its APS application process rather than waiting until the final months.

Provider choice is part of the strategy

A survivor may prefer to use the deceased’s existing manager for administrative convenience or choose another provider for fees, investment range or service. The receiving provider must agree to accept APS. Once an APS subscription is made with a manager, later subscriptions up to the APS limit generally have to stay with that manager, so choose carefully before starting a series of payments.

Non-cash assets need extra care

HMRC allows certain inherited non-cash ISA assets to be used for an APS subscription in specie where the conditions are met. That means a survivor may not need to sell a qualifying inherited investment before using it for APS with the relevant manager. Ownership, asset type and the identity of the ISA manager all matter, so this is not a general “transfer anything” rule.

Do not confuse APS with the annual £20,000 limit

APS sits on top of the ordinary ISA subscription framework. It is therefore possible for the survivor to make a regular ISA subscription and a separate APS subscription, subject to the rules of each. The two allowances should be tracked separately in the paperwork.

Questions to ask an APS provider

Do not compare APS providers only on the headline interest rate or investment menu. Ask whether the provider accepts APS at all, what evidence of the deceased ISA it requires, which valuation date it uses in the application, whether it accepts cash or inherited investments in specie, and what transfer or dealing charges apply. Some providers may also have minimum balances or account-opening requirements. Because HMRC permits APS with the same manager or another manager willing to accept the subscription, provider selection is a genuine planning decision rather than a mandatory continuation of the deceased person's account.

Keep the estate paperwork linked to the APS application

The executor and surviving spouse or civil partner should retain the deceased ISA statement, date-of-death valuation information, correspondence with the manager and evidence of any APS subscription. That audit trail helps resolve the common problem of confusing ordinary ISA subscriptions with the separate permitted amount. It is particularly important where there are several ISAs, multiple beneficiaries or an estate that takes months to administer. A provider can ask for specific documents, so start the conversation early rather than discovering a missing valuation or identity document close to an APS deadline.

APS should also be distinguished from simply transferring an existing ISA between managers. A transfer moves an ISA under the transfer rules; an APS is a permitted subscription made by the surviving spouse or civil partner against the separate APS allowance. Using the wrong process can create unnecessary confusion, especially where inherited investments are being moved between platforms. Ask the receiving provider which application form and transfer route it requires before selling or moving anything.

Worked example

Example: A spouse dies with an ISA valued at £80,000 for APS purposes. The surviving partner has also used £6,000 of the normal annual ISA subscription allowance. The £80,000 APS is a separate permitted subscription route; it is not reduced to £14,000 simply because £6,000 has already been subscribed normally.

If the survivor then makes a £20,000 normal ISA subscription and an £80,000 APS subscription with an accepting manager, the nominal combined amounts are £100,000, illustrating why the two allowances must be recorded separately.

The £100,000 combined figure is not a new annual allowance. It simply demonstrates how an APS subscription can sit alongside an ordinary subscription when the statutory conditions and provider procedures are satisfied.

What is an Additional Permitted Subscription?#

It is an extra ISA subscription allowance available to the surviving spouse or civil partner of a deceased ISA investor. It sits outside the ordinary annual subscription limit. When an ISA holder dies, the surviving spouse or civil partner can receive an Additional Permitted Subscription allowance on top of the normal annual ISA subscription limit.

Does the survivor have to inherit the ISA to get APS?#

No. HMRC says the APS is available whether or not the survivor inherited the deceased person’s ISA assets. HMRC allows certain inherited non-cash ISA assets to be used for an APS subscription in specie where the conditions are met. Because HMRC permits APS with the same manager or another manager willing to accept the subscription, provider selection is a genuine planning decision rather than a mandatory continuation of the deceased person's account.

How much is the APS allowance?#

It is generally based on the deceased ISA’s value under the relevant rules and valuation date. Multiple-ISA cases have specific HMRC calculation rules. For a single deceased investor’s ISA, the APS calculation can be based on the ISA value at the relevant date under the regulations.

Can I use another provider for APS?#

Yes, provided the other ISA manager agrees to accept the APS. Check the provider’s application process before transferring or subscribing. Because HMRC permits APS with the same manager or another manager willing to accept the subscription, provider selection is a genuine planning decision rather than a mandatory continuation of the deceased person's account.

What is the cash APS deadline?#

For cash subscriptions, HMRC guidance provides three years from the date of death, or 180 days after completion of estate administration if later. The deadline can be affected by when estate administration is completed, so record both the death date and the administration-completion date when planning the application.

Can inherited investments be used without selling them?#

Certain inherited non-cash ISA assets can be used for an APS subscription in specie when HMRC's conditions are met, so you may not need to sell them first. Ownership and manager requirements must be satisfied, and non-cash inherited assets have additional timing rules, so check the ISA manager's process before acting.

Is APS part of the £20,000 annual ISA allowance?#

No. APS is an additional permitted subscription route for the surviving spouse or civil partner, separate from normal annual ISA subscriptions. When an ISA holder dies, the surviving spouse or civil partner can receive an Additional Permitted Subscription allowance on top of the normal annual ISA subscription limit.

Keep reading

Next question →Why is probate delayed and how long does it take?

Sources

  1. HMRC: Manage Additional Permitted Subscriptions
  2. HMRC: Manage ISA subscriptions
  3. GOV.UK: Individual Savings Accounts
  4. MoneyHelper: Bereavement and inheritance

Figures were checked against these sources before publication. If a rule changes, we update the page and show the new date.

General information, not personal financial advice. Rules depend on your circumstances; check the official source or speak to a regulated adviser before acting.