UK Pensions Law Update - February 2026

Autumn Budget

Summary

The Autumn Budget announced a series of reforms affecting UK pensions.

Direct payments to members out of defined benefit (DB) surpluses

From April 2027, “well-funded” defined benefit schemes will be able to pay surplus funds directly to members over normal minimum pension age on a tax authorised basis, subject to scheme rules and trustee approval. Such payments will be taxed as pension income at the member’s marginal rate.

Inheritance tax (IHT) changes for unused pension funds and death benefits

From April 2027, most unused pension funds and death benefits will be included in the estate of a deceased for IHT purposes. Concessions to personal representatives include the ability to instruct scheme administrators to withhold 50% of taxable benefits for up to 15 months from the date of death to cover IHT.

Salary sacrifice NICs exemption capped

From April 2029, only the first £2,000 of salary sacrificed per annum in exchange for employer pension contributions will be exempt from National Insurance contributions (NICs), with both employer and employee NICs being due on amounts above this cap. Employers will be required to report total salary sacrifice amounts via payroll.

Pre-97 indexation for PPF and FAS members

From January 2027, Pension Protection Fund (PPF) and Financial Assistance Scheme (FAS) members will receive CPI-linked increases (capped at 2.5% a year) on pre-1997 pension accruals, where their original scheme provided this benefit. The PPF believes that this reform will affect over a quarter of a million PPF and FAS members.

Further detail is available here.

Comment

The Autumn Budget 2025 brings a mix of opportunity and challenge for the pensions sector.

The ability to pay members direct lump sum payments out of DB surplus will be welcomed by many employers and trustees looking to reach agreement on efficient surplus sharing.

Bring unused pension funds into the IHT net, and restricting the tax efficiency of salary sacrifice arrangements will, however, cause additional administrative burden and likely cause sponsors to review scheme design.

It will be important for trustees and employers to assess the practical impact of these changes and to remain agile as further details and guidance emerge.  

PO Cases

Ms N

Facts

Ms N complained about the distribution of lump sum death benefits from her father’s pension scheme.

After his death, Ms N’s brother completed a claim questionnaire, stating he was the only child and that there were no other potential beneficiaries. Relying on this information, the scheme administrator paid the full lump sum of £61,514 to the brother.

Two years later, Ms N notified the new scheme administrator that her brother’s claim was fraudulent and that the previous administrator had ignored an existing nomination form, which should have raised a red flag that there were other potential beneficiaries. The new administrator asserted that the payment to the brother had been made in good faith and suggested Ms N seek legal advice to recover the funds from her brother, who was subsequently convicted of fraud.

Decision

The Deputy Pensions Ombudsman upheld the complaint, finding that the scheme administrator had not adequately considered all potential beneficiaries before making the payment and had failed to establish all relevant facts by making further enquiries. While it was not necessary to exhaustively identify every possible beneficiary, proper consideration was required. The error was deemed “sufficiently material” to warrant intervention.

The new scheme administrator was directed to carry out appropriate enquiries to identify potential beneficiaries, gather relevant information, and reconsider the previous decision, disregarding the fact that payment had already been made to the brother. See the Ombudsman’s Determination here.

Comment

This case highlights the importance of scheme administrators conducting thorough checks to identify all potential beneficiaries before distributing death benefits.

Whilst proportionate approaches are reasonable, administrators should be live to the possibility of fraud and the need to take extra steps in certain cases (particularly where an individual claims to be the sole beneficiary) to ensure proper information is obtained.

Mr R and Mrs T

Facts

Mr R and Mrs T each complained that their scheme administrator/trustee failed to carry out sufficient due diligence and warn them of potential scam risks before transferring their final salary pension benefits in around 2013 to what turned out to be pension liberation schemes.

Both had been cold-called by unregulated entities and persuaded to transfer their benefits — Mr R to a qualifying recognised overseas pension scheme (QROPS) and Mrs T to a small self-administered scheme (SSAS ) for an overseas property investment.

Both received statutory transfer value quotes with the Pensions Regulator’s warning note and Scorpion Leaflet, and the transfers proceeded after confirmation of the receiving schemes’ HMRC registration.

Decision

The Deputy Pensions Ombudsman dismissed both complaints, concluding that where members have a statutory right to transfer and the statutory requirements are satisfied, the administrator or trustee is obliged to act on the transfer request in the absence of scam warning signs.

There is no general duty of care to conduct further due diligence beyond the regulatory guidance that applied at the time of transfer.

In Mrs T’s case, the Deputy Pensions Ombudsman declined to follow the High Court’s decision in Hughes v The Royal London Mutual Insurance Society Ltd [2016] EWHC 319 (Ch), finding that Mrs T did have a statutory transfer right as an “earner”. The respondents were not responsible for the members’ losses.

See the Ombudsman’s Determinations regarding Mr R here and Mrs T here.

Comment

The Deputy Pensions Ombudsman expressed considerable sympathy for the complainants but found that the schemes had complied with the relevant regulatory guidance at the time (in 2013). The statutory transfer regime changed on 30 November 2021 to allow trustees to halt statutory transfers that present similar concerns.

Mr E

Facts

Mr E complained that he had received incorrect benefit statements from his pension scheme, which included an extra five years’ pensionable service and inflated pension and lump sum calculations. He raised the discrepancy with the administrator, who assured him the figures were correct. Relying on this information, Mr E decided to leave his senior teaching role for part-time consultancy work. The error was only discovered when he applied for his pension to be put into payment, at which point his pensionable service was corrected and his benefits reduced.

Decision

The Pensions Ombudsman upheld the complaint, finding that the administrator had provided incorrect information which Mr E had reasonably relied upon in making retirement decisions – including retiring early. The administrator’s disclaimer that the figures were for illustration only did not absolve it of responsibility, particularly given the verbal assurances provided.

The Ombudsman directed the administrator to pay Mr E a substantial lump sum sufficient to put him in the position he would have been in had the inaccurate information not been provided, and £1,000 for distress and inconvenience. See the Ombudsman’s Determination here.

Comment

This case highlights the importance of accurate benefit statements and the limitations of disclaimers where members have proactively questioned the estimates received and relied on verbal assurances that the information given is correct.  

Cases

High Court approves complex settlement of pension scheme validity issues

Outline

The High Court has approved a novel settlement and granted rectification in a case involving multiple validity issues affecting a pension scheme’s benefit changes over nearly two decades. The scheme had undergone numerous amendments between 1993 and 2011, many of which reduced benefits, but several documents suffered from execution defects, potential non-compliance with section 37 of the Pension Schemes Act 1993, or drafting errors with unintended consequences.

The parties — the trustee, employer, and a representative beneficiary — structured the settlement around 13 specific “junctures” representing outstanding disputes on validity and section 37 compliance. Each juncture was assigned a statistical probability for each possible outcome were it to be litigated before the Court, determined through negotiation. The settlement provided for additional benefits to members, reflecting the possibility that they might have higher entitlements than those received under the scheme’s administrative practice (which assumed that all amendments were valid).

The Court was satisfied that the parties had exercised “extreme care” to ensure the settlement produced realistic results, taking into account tax implications and the interests of all stakeholders.

Certain of the amendments were defective because the drafting did not reflect the parties’ intentions. In relation to these amendments, the Court found that the trustee had established the necessary subjective intention for rectification to succeed. The evidence showed that these apparent increases in benefits were inadvertent and unintended, and the scheme had been administered consistently with the documents as the trustee sought to have them rectified.

Decision

The High Court approved the settlement, holding that it was within the range of reasonable outcomes and would benefit all represented persons. The Court also granted rectification of the relevant scheme documents, accepting that the parties’ intentions had not been properly reflected due to drafting errors.

Comment

Some pension schemes find them in the unfortunate position that a number of amendments made over many years might be invalid. Testing the validity of each successive amendment in Court would be a very costly process – with no certainty as to the ultimate outcome for various groups of members until the Court has considered each amendment in detail.

The parties in this case reached a more pragmatic solution by reaching agreement as to the probability of a Court finding for or against the validity of each relevant amendment. The Trustee then sought Court approval of the settlement as reasonable from a member perspective.

The Court’s willingness to approve a settlement based on a probabilistic assessment of litigation risk — rather than a binary “valid/invalid” approach to each individual amendment — demonstrates a recognition that a settlement could offer members additional benefits, without waiting for the outcome of costly litigation which might ultimately lead to no additional member benefits.

For further detail, see here Places for People Pension Trustee Ltd v Places for People Group Ltd.

High Court considers validity of closure to future accrual

Facts

The High Court was asked to interpret a restriction (“fetter”) in the amendment power of the 3i Group Pension Plan and whether this prohibited an amendment closing the scheme to future accrual back in 2011.

The case was brought by the Trustee because the Court of Appeal had found in BBC v BBC Pension Trust Ltd [2024] EWCA Civ 767 that a restriction on amendments which prejudiced members’ “interests” could (depending on the precise nature of the restriction) prevent an amendment to terminate future service accrual. The Trustee in this case wanted to confirm, before the Scheme was wound up, that it has been properly closed to future service accrual in 2011.

Decision

This case was distinguished from BBC v BBC Pension Trust Ltd [2024] EWCA Civ 767, where broader language protected ongoing accrual terms.

Here, the fetter was more narrowly drafted, only preventing changes that would diminish past service benefits. The Court held that as the amendment closing the scheme to future accrual preserved the link to final pensionable salary for accrued benefits, the amendment did not breach the fetter and was valid.

Comment

This decision highlights the importance of the precise wording of amendment powers and fetters in pension scheme rules.

For further detail, see here 3i plc v Decesare [2025] EWHC 3023 (Ch) (21 November 2025).  

Legislation, guidance and consultation

DWP consultation on the future of pension scheme trusteeship

Current Status and next steps

On 15 December 2025, the DWP launched a consultation on the future shape of trust-based pension scheme governance. The consultation, which closes on 6 March 2026, builds on the 2023 call for evidence on trustee skills, capability and culture and focuses on delivering fewer, larger, “better” schemes run by highly skilled, diverse and independent trustee boards, with robust governance and effective management of conflicts.

Key themes include:

Role of trustees: Whether boards currently have sufficient expertise to deal with increasingly complex decisions and protect members’ interests, what barriers exist to good trusteeship, and what additional support may be needed for lay trustees.

Role of administrators: How administrators should be regulated and governed in a landscape moving towards larger DC “mega funds” by 2030, including potential extension of the Pensions Regulator’s remit, a possible registration regime and minimum standards.

Improved standards: Potential higher knowledge standards and formal accreditation for independent trustees, and views on introducing a new “public trustee” that the Regulator could appoint where trustees need to be replaced or for orphan schemes.

Comment

This consultation signals a further ratcheting-up of expectations around trusteeship, with a clear policy direction towards professionalisation and consolidation.

Proposals affecting lay trustees, independent trustees and administrators could materially reshape how schemes are governed in practice, particularly for smaller DB and DC schemes that currently rely heavily on lay trustee engagement and outsourced administration. We await the outcome of the consultation in due course.

You can find the consultation here.

Pensions dashboards – December 2025 progress update and data readiness

Outline

On 9 December 2025, the Pensions Dashboards Programme (PDP) published its latest progress update report. Around 700 pension providers and schemes have now connected to the dashboards ecosystem (about three quarters of those in scope), with State Pension data also connected. The first phase of controlled consumer testing of the MoneyHelper Pensions Dashboard began in August 2025 and is now past its halfway point, receiving broadly positive early feedback. The Government has reaffirmed that the MoneyHelper dashboard will launch before any private sector dashboards, and that it remains committed to enabling private dashboards once the service is proven to be safe, secure and reliable.

Alongside this, TPR has intensified its focus on data readiness following a large scale engagement exercise with hundreds of schemes, which found “significant progress” on data quality but also identified that some schemes still have “more to do”. TPR has particularly focused on value data and digitisation, finding that many schemes carry historical “data debt” – due to past underinvestment in maintaining member records.

TPR has since issued revised scheme member data quality guidance emphasising that trustees are ultimately accountable for data quality, and that they must carry out regular data assessments, report accurate scores and put structured improvement plans in place, signalling that that trustees who cannot evidence appropriate data governance and improvement activity may face formal interventions such as improvement notices.

All in scope schemes and providers are required to connect by 31 October 2026, and although the DWP connection timetable is non statutory, the DWP, TPR and the FCA all expect schemes to be able to demonstrate they have had regard to it.

Comment

For trustees and providers, the strategic risk in relation to pension dashboards is no longer whether they will happen, but whether their scheme will (i) be ready in time for the deadline and will (ii) present accurate, comprehensible data when exposed to members at scale.

Regulators are clearly focusing on data readiness for dashboards and TPR’s new guidance confirms that dashboards readiness will be a litmus test for wider governance under the General Code.

Schemes will therefore need to ensure they are prepared for connection (using TPR guidance and PASA materials to improve their data) and begin considering member facing communications and processes to handle issues such as pending/possible matches and discrepancies once dashboards are live.

You can find the PDP progress report here and the TPR report on data readiness here.

Pensions Regulator intervention report into Northern Foods

Current Status and next steps

TPR has published a report on its intervention in the Northern Foods Pension Scheme. The intervention was prompted by concerns over the employer’s ability to support the scheme following the sale of several businesses and the use of sale proceeds to refinance group debt rather than improve scheme funding.

TPR concluded that the scheme had been treated less favourably than other stakeholders, particularly in the context of related-party transactions benefiting the wider corporate group. Following regulatory engagement, a comprehensive support package was agreed, including the replacement of the statutory employer with a stronger entity, a commitment to pay approximately £300 million in contributions by 2034, and the provision of extensive guarantees covering all scheme liabilities.

Comment

This case underscores the Regulator’s proactive approach in protecting scheme members’ interests, particularly where there is evidence of inequitable treatment compared to other stakeholders. The outcome demonstrates the importance of robust employer covenant support and the Regulator’s willingness to secure enhanced protections (including via the threat of financial support directions) where necessary.

For more detail, see: Northern Foods Pension Scheme - Regulatory intervention report.

Inheritance tax and pension fund death benefits – Finance Bill 2026

Outline

On 4 December 2025, the Government published a draft Finance Bill which included details of its proposals for the taxation of pension fund death benefits. At present most pension fund death benefits are not included in a deceased’s estate for inheritance tax (IHT) purposes. From 6 April 2027, most of these benefits will be included in a deceased’s estate – and potentially subject to a 40% IHT charge.

There are four express exclusions:

1. Death in service benefits payable in respect of an employee in service.

2. Dependants’ pensions payable to surviving spouses, children and other dependants on a member’s death.

3. Annuities for a dependant or nominee bought at the same time as an annuity for the member.

4. Trivial commutation lump sum death benefits that extinguish a person’s right to a dependant’s pension.

Payments to spouses and to charities will also continue to be exempt from inheritance tax.

Comment

From an employee benefits perspective the exclusion of lump sum death in service benefits is important and the current practice of paying these under discretionary trusts is likely to continue unchanged – but these benefits should be reviewed to ensure they meet the detailed new statutory requirements for them to be excluded from the IHT charge.

A significant effect on employer sponsored pension schemes will be in respect of lump sums payable on the death of a deferred or pensioner member – e.g. lump sums payable on the death of pensioner within five years of retirement. Consideration will need to be given to how the potential tax liability might be mitigated.

ICO publishes updated guidance on international data transfers

Outline

The Information Commissioner's Office (ICO) has released revised guidance on transferring personal data internationally, aiming to simplify compliance with the UK GDPR and the Data Protection Act 2018.

The updated materials are now divided into targeted sections, addressing topics such as the process for international transfers, adequacy decisions, safeguards, risk assessments, exceptions, and data received from the EEA. The guidance also reflects terminology and requirements introduced by the Data (Use and Access) Act 2025.

The updated guidance continues to use a three-stage process to assess whether a data transfer is subject to restrictions. It also provides further detail and clarification on frequently queried topics, such as the territorial reach of the UK GDPR and the concept of "initiating" the transfer. The guidance now places emphasis on the act of "initiating" a transfer, rather than both "initiating and agreeing" it.

The ICO will be holding a webinar in March 2026 to support the launch of the updated guidance, and intends to introduce an interactive tool and further examples in due course.

Further information is available here: Updated guidance on international transfers.

Comment

The revised guidance is designed to offer clearer, more practical direction for pension schemes and other organisations handling cross-border data transfers.

The inclusion of practical tools and scenarios should make it easier for organisations to understand and meet their obligations.

Pensions scheme trustees who transfer data internationally (often in the context of scheme administration) are encouraged to familiarise themselves with the new guidance and consider participating in the upcoming webinar to stay up to date with their compliance duties.

Pensions Ombudsman issues new guidance on pension overpayments

Outline

On 16 December 2025, the Pensions Ombudsman published “Pension overpayments: Information for members”, a practical guide to assist pension scheme members facing overpayment issues.

The guidance clarifies the Ombudsman’s approach to overpayments, repayment obligations, and available defences such as change of position, estoppel, and delay. It also sets out the types of evidence required to support a defence and reminds members of the relevant legal time limits for recovery actions.

Comment

This resource provides valuable clarity for members and schemes alike, promoting early resolution of overpayment disputes and highlighting the evidential requirements for common defences. It also reinforces the importance of prompt communication and record-keeping by both schemes and members in the context of overpayments.

For more detail, see: Pension overpayments - Information for members.

Pensions Schemes Bill 2025: Delegated Powers and Regulatory Reform Committee Comments on “skeletal” Bill

Outline

Both the House of Lords Delegated Powers and Regulatory Reform Committee (DPRRC) and the Constitution Committee have issued reports criticising the Pension Schemes Bill 2025 as “skeleton” legislation. The Bill’s 123 clauses confer 119 delegated powers, supported by a 149 page delegated powers memorandum, leading the DPRRC to describe it as a licence for ministers (and others such as the FCA) to “fill in all the gaps” in the primary legislation, which, in turn, makes meaningful scrutiny difficult. The DPRRC characterises this as giving ministers a “blank cheque” and notes the absence of any explicit statement that this is a skeleton Bill, or a detailed justification for that approach.

The Constitution Committee endorses the DPRRC’s conclusions and points to Cabinet Office guidance that “skeleton” clauses are rarely appropriate without exceptional justification. It warns that the framework nature of the Bill will inhibit effective scrutiny of its intended effects and invites the House to press the Government further.

The Bill continues its passage through the House of Lords.

Comment

These reports underline the fact that, above all, the Pension Schemes Bill 2025 is best understood as an enabling framework: the real impact of the policies will be determined largely by subsequent regulations rather than by the primary legislation itself.

The fact that the majority of the policy making has been shifted into regulations may lead to uncertainty on the effect of the Bill in the short term, but does provide scope for trustees, employers and providers to influence outcomes in the regulatory phase through the consultation and rule making process.

You can find the committee report here.

Collective Defined Contribution (CDC)

Summary

The final quarter of 2025 saw developments in relation to collective defined contribution (CDC) schemes.

Retirement CDC schemes

In October, the Department for Work and Pensions (DWP) launched a consultation on creating a new category of CDC scheme. “Retirement CDC schemes” would be open only to pensioner members and set up as unconnected multiple employer schemes. The existing CDC regulatory framework will be modified to accommodate such schemes, which would need to be authorised by the Pensions Regulator. The consultation closed in December.

Unconnected multi-employer CDCs

In October, the DWP also published its response to the October 2024 consultation on extending CDC provision to unconnected multi-employer schemes (UMESs). Most respondents supported the proposals, and regulations were made in December to accommodate these. The new regulations introduce additional authorisation, governance, and financial sustainability requirements, including a new “scheme proprietor” role. Also in December, the Pensions Regulator launched a consultation on a revised code of practice for CDC schemes, extending coverage to unconnected multi-employer scheme. The consultation closed on 13 February 2026.

House of Commons Library briefing on CDC schemes

In November, the House of Commons Library published a research briefing paper providing an overview of CDC schemes in the UK. The paper reviews the legislative framework and recent policy developments, including the extension to unconnected multi-employer schemes and proposals for retirement-only CDC schemes. It also highlights growing interest in CDC as a default option for guided retirement.

Comment

The recent flurry of CDC-related activity highlights the government’s commitment to expanding collective DC pension options in the UK. Ongoing engagement with regulatory developments will be key to making the most of these opportunities.

Boxclever – TPR report on regulatory intervention

Current Status and next steps

The Pensions Regulator has published a regulatory intervention report confirming a settlement of its long running financial support direction proceedings against ITV in relation to the Boxclever Group Pension Scheme.

Box Clever was created in 2000 as a joint venture between Granada (now ITV) and Thorn aiming to combine their TV rental businesses. The venture failed and entered administration in 2003, with the scheme entering a PPF assessment period in November 2014 and having its benefits restricted to PPF levels.

After failed attempts by the trustees to return members to the original schemes, TPR issued a warning notice in 2011 and its Determinations Panel decided it was reasonable to issue financial support directions (FSDs) to ITV plc and four associated Granada entities. ITV unsuccessfully challenged that decision through the Upper Tribunal and Court of Appeal, with the Supreme Court refusing permission to appeal.

FSDs were issued in March 2020 - requiring suitable support to be put in place. When no acceptable support package was agreed, TPR issued a contribution notice (CN) warning notice in 2022 for the scheme’s full buy out deficit (then around £120 million).

In July 2024 the parties settled, and roughly 2,800 Boxclever members were bulk transferred to the ITV Pension Scheme with back payments (plus interest) above PPF levels. This transfer completed on 1 October 2025, so members are now expected to receive full scheme benefits.

Comment

The case underlines the reach of TPR’s anti avoidance powers and its readiness to litigate over many years.

The first use of a CN warning notice for the full buy out deficit, followed by a negotiated bulk transfer delivering full benefits, illustrates TPR’s twin strategy of using its statutory powers while remaining open to settlement where this secures better member outcomes than PPF compensation.

You can find the full TPR report here.

HMRC publishes guidance on checking whether members hold protected allowances

Outline

HMRC has published guidance for scheme administrators on how to check and record members' protected allowances, and the process for submitting an event report if a lump sum (or lump sum death benefit) is paid that exceeds a member’s available lump sum allowance.

The guidance provides a step-by-step process for checking a member's protected allowance, including use of the administrator look-up service.

Comment

The guidance should make dealing with members with protected allowances more straightforward and help administrators comply with new reporting requirements following the removal of the lifetime allowance.

Administrators should review the guidance and update their procedures as needed to reflect these changes.

Pensions Regulator publishes revised guidance on scheme administration

Current Status and next steps

On 9 December 2025, the Pensions Regulator (“TPR”) published revised guidance on the administration of pension schemes. The updated guidance applies to all scheme types and sets out practical steps for trustees to meet TPR’s expectations under the General Code of Practice.

Key changes include a new expectation for governing bodies to have a written administration policy (or strategy) covering the scope of administration functions, monitoring and review procedures and the process for appointing administrators. The guidance also emphasises the need for trustees to understand their scheme’s IT systems and data flows, and to ensure robust governance and control frameworks, particularly in light of technological developments such as AI. See the guidance here for further details.

Comment

Trustees should be aware that TPR now expects them to have a written administration policy in place, whether administration is outsourced or managed in-house. This means trustees will need to review and, if necessary, update their current practices to ensure they are clearly documenting administration processes, monitoring performance and regularly reviewing their administrators’ suitability and resources.

Trustees must also ensure they understand the technology used in scheme administration and have appropriate controls in place to manage risks, especially as the use of AI and other technologies increases. Ultimately, these changes reinforce that trustees remain legally responsible for scheme administration and must take an active role in oversight to ensure good outcomes for members.  

At a glance updates

Pensions Regulator launches engagement initiative exploring investment in growth assets by pension schemes

The Pensions Regulator has launched an initiative to examine how pension schemes approach investment in UK private market and infrastructure growth assets. The Regulator is engaging with key market participants to identify opportunities, vehicles, and barriers, and will publish its findings in a market oversight report in 2026.

For more detail, see: TPR probes barriers to investment in private markets and infrastructure that could deliver better returns for savers.

HM Treasury’s Regulation Action Plan: pensions aspects

On 21 October 2025, HM Treasury published an update on its Regulation Action Plan. Updates on the Pensions Regulator’s pledges include a review of master trust capital reserves, the launch of an Innovation Support Service, steps to reduce regulatory burdens, and ongoing work with the DWP on value for money reforms and DC scheme consolidation. Further guidance is expected by early 2026.

For more detail, see here.

Auto-enrolment thresholds unchanged for 2026/27

On 18 December 2025, the Pensions Minister, Torsten Bell confirmed that the automatic enrolment thresholds for 2026/27 will remain unchanged from 2025/26, with the earnings trigger at £10,000, the lower earnings limit at £6,240, and the upper earnings limit at £50,270. This follows the statutory annual review.  

UK Pensions Horizon Scanning

A reminder of key upcoming developments in the UK pensions space.

2026 developments

Collective Defined Contribution (“CDC”) Schemes Regulations and updated TPR Code of Practice

Regulations extending collective defined contribution (CDC) provision to unconnected multi-employer schemes and TPR updated Code of Practice are set to come into force on 31 July 2026

Pension Schemes Bill

Is expected to receive Royal Assent in mid 2026

2026 onwards

31 October 2026

Pension dashboards

Mandatory final connection deadline for all in-scope schemes

6 April 2027

Inheritance Tax changes for pensions

Payment of DB surplus direct to members permitted

DB – 2027

Surplus flexibilities to come into force, with DWP to consult on draft regulations in late 2026

6 April 2028

Increase in Normal Minimum Pension Age

The minimum age at which most people can access their pension will increase from age 55 to age 57

DC - 2028

First VfM assessments will be required, with DWP to consult on draft VfM regulations in 2026/27

DB - 2028

Superfunds regulations to come into force, with DWP to consult on draft regulations in early 2026

5 April 2029

Expiration of Lifetime Allowance Statutory Override

The override facilitates the retention of limits under scheme rules which have been drafted by reference to the Lifetime Allowance

6 April 2029

Salary sacrifice changes come into effect

Amount that is exempt from National Insurance contributions (NICs) will be capped at £2,000 a year for employee contributions made via salary sacrifice

DC – 2030

Small pots transfer duties to come into force, with DWP to consult on draft regulations in 2027/28

DC Master Trusts and Group Personal Pension Schemes - 2030

Scale requirements to come into effect

RPI alignment with CPIH – 2030

Mansion House Accord – 2030

Seventeen defined contribution pension scheme providers express their intent to invest at least 10% of their DC default funds in private markets by 2030, with 5% of the total allocated to UK private markets.