The great thing about current ISA rules is the flexibility to save the full allowance in either cash or investments – or a blend of both. This tax year, savers can split their allowance across different types of ISA, whether that’s a Stocks & Shares ISA, a Cash ISA, a Lifetime ISA (up to £4,000 for those who qualify) or an Innovative Finance ISA.
That flexibility will narrow from April 2027 when subscriptions to Cash ISAs will be capped at £12,000. The ability to sidestep that rule by holding cash inside a Stocks & Shares ISA – a workaround currently permitted - will also change. For those under 65, HMRC has pledged to ban transfers from Stocks & Shares ISAs to Cash ISAs, apply a charge on interest earned on cash held in investment ISAs and curb access to investments deemed ‘cash like’, which may remove access to money market funds. These proposals, alongside the new Cash ISA cap itself, have prompted several post-Budget discussions between policymakers and providers as the finer details are worked through.
One option reportedly under consideration is a flat rate charge on interest earned on cash held within Stocks & Shares ISAs, with some reports it would be a rate of 22%, similar to the 20% charge applied to cash held in investment ISAs prior to July 2014, The latter went largely unnoticed due to the ultra-low interest rates at the time and with many ISA providers paying no interest at all. Applying a charge now would be felt, both due to higher Bank of England rates and much improved terms from ISA providers following regulatory pressure. A charge for holding cash would be a barely disguised tax and goes against the tax-free promise of ISAs. Occasional cash holdings are perfectly normal in Stocks & Shares ISAs, representing money awaiting investment, dividend distributions and temporary positions to reduce risk in times of turbulence.
Separately, replacing the Lifetime ISA (LISA) with a simpler alternative has merit as its dual purpose – supporting first-time buyers and boosting retirement savings – has long created complexity. Restrictive purchase rules, including the £450,000 cap on the value of a qualifying first home, have been problematic for some prospective buyers, particularly in London and the South East. For now, however, LISAs can still be opened and topped up under existing rules, which can be lucrative as there is the opportunity to secure a maximum £1,000 annual uplift - 25% of their contribution.
Savers can also access peer-to-peer lending through an Innovative Finance ISA (IFISA), allowing people to lend up to £20,000 to borrowers or businesses free from tax. From April, cryptocurrency exchange traded notes will theoretically be available within IFISAs should any providers choose to offer access to them. However, it should be noted that IFISAs are not protected under the Financial Services Compensation Scheme.
While some savers may be tempted to maximise their Cash ISA entitlement before the new rules take effect, it’s worth remembering that investments, especially equities, have historically delivered higher real returns than cash over longer periods, though can be volatile over the short-term.
That said, investing is not suitable for everyone. Investors typically need a time horizon of at least five years to ride out market ups and downs, and there are periods when holding cash makes sense – such as planning a short-term financial goal such as clearing a mortgage. But leaning too heavily on cash for the long-term risks missing out on the inflation-beating returns that well-diversified investments have typically delivered over time.