The date that an individual is regarded as having first flexibly accessed his pension rights is determined as follows;

immediately before the first ‘qualifying payment’ is made from a member’s flexi-access drawdown fund where that fund came into being as a result of a designation (see ¶392-520) on or after 6 April 2015 or a recognised transfer to a new registered scheme (see ¶380-000) (FA 2004, s. 227G(2));

midnight on 5 April 2015, where the individual had previously fulfilled the flexible drawdown conditions (see ¶378-300) (FA 2004, s. 227G(3));

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