Income over 100k and tax free childcare - do pension overpayments need to be made now?

[stellarnova]

DH has earned over 100k ever since we've claimed tax free childcare but salary sacrifice has always taken him below. We haven't had any issues claiming it so far. However, he recently changed jobs and a hiccup with salary sacrifice means he will likely be just over 100k by the end of the tax year, unless he makes some lump sum contributions to his pension and gift aid donations (which he will do).

HMRC quickly picked up on this and have stopped our support until we can provide more information on his income. We replied saying that his income would be brought below the threshold through him doing a combination of the above by the end of the financial year. HMRC have now replied as below. Does anyone know how much detail they likely need in order to reinstate it, given that there are still a number of unknowns at this point in the year (e.g. will he get a pay rise or bonus, what will his interest from savings etc)? i.e. do we have to give exact figures and/or make some of the additional payments now in order to stay eligible, or is it likely enough to answer yes/no to their questions and then reiterate in more general terms that he will be taking steps to stick below the £100k threshold (e.g. "his monthly income is expected to be reduced to x through salary sacrifice, and he is expecting to pay at least the surplus of y into his pension and/or through charitable contributions?)? Thanks for any help!

"Before we can decide on whether you are eligible for Tax Free Childcare and Free Childcare for Working Parents for X we need you to provide further information regarding your partner's adjusted net income for the 2025/2026 tax year. Please confirm the monthly taxable income from employment and any expected bonus payments to be received within the above tax year. Please confirm if any other taxable income is to be received within the above tax year. Please confirm if any payments to a private pension or donations to registered charities will be made within the above tax year. Please confirm if there will be an increase to pension contributions via the employment salary within the above tax year. If any adjustments to the above contributions will be made, please advise when this change will take place. Please confirm the amount of any employer benefits expected to be received within the above tax year. What to do next: If your partner has made payments to a private pension or donations to registered charities. You can send the evidence online at www.gov.uk/guidance/challenge-a-childcare-service-application-decision. If your partner has not yet made payments or does not intend on making any payments, please call us on Y and quote your National Insurance number. Next steps: If we do not hear from you by Z, we will make a decision based on the information we already have."

If he is definitely going to be below £100k because he is going to put the exact amount into his pension to make sure he will be below, I’d reply with the relevant estimates that make that work.
Eg (simplified version of course)

Salary: £120k
Bonus (estimate): £10k
Pension contribution: £31k made up of £x monthly contributions plus two lump sums of £y now and £z in March.

I’ve assumed that he might as well make a lump sum payment to his pension now, because you’ve said he will be over it’s just not clear by how much? So I’d do the lump sum for what you think the minimum that will be needed is now, and then add more later if necessary.

Would also advise that he makes a lump sum payment based on what he he thinks will bring him below the threshold and advise HMRC. Obviously this depends on affordability. My DC are older so the childcare cost issue isn’t relevant to me but I’ve paid about £30k into a private pension to reduce my taxable income as I’m currently in the 45% higher income tax band. It’s difficult to know exactly how much to pay as I receive bonuses and the amount varies so I’ve guessed.

I’d also advise you do put on a hard hat as someone will be along soon enough to tell you that you shouldn’t get any free childcare with all that money, they have to survive on £20k a year, it’s unfair wealthy people can game the system etc. On MN there is a lack of understanding as to how the tax system works as well as a dislike of higher earners.