Pensions Weekly Update

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Here is our weekly summary of key legal and regulatory developments relevant to occupational pension schemes that you might have missed, with links for further information.

The Pensions and Lifetime Savings Association, the Association of British Insurers (ABI) and the City of London Corporation have led on a voluntary initiative called the Mansion House Accord. This follows on from the 2023 Mansion House Compact. There are currently 17 signatories to the new commitment, which is to allocate at least 10% of defined contribution (DC) default funds to private markets by 2030 and, within that, at least 5% of the total going to UK private markets, assuming a sufficient supply of suitable investible assets for providers. The commitment is subject to fiduciary duties and the consumer duty and is dependent on supporting actions by government and regulators. The current signatories are Aegon UK, Aon, Aviva, Legal & General, LifeSight, M&G, Mercer, NatWest Cushon, Nest, now:pensions, Phoenix Group, Royal London, Smart Pension, the People’s Pension, SEI, TPT Retirement Solutions and the Universities Superannuation Scheme (USS). The ABI says that based on providers’ current investment holdings, total pension assets in the scope of the agreement amount to £252 billion.
The Pensions Regulator (TPR) has updated its guidance on making third-party applications. The guidance includes information about when a person can make an application to TPR to use its powers (for example, the power to appoint an independent trustee), details how the application will be progressed, explains the need to provide evidence to support the application and includes links to various application forms and further information.
The Pensions Administration Standards Association (PASA) has issued dashboards guidance covering circumstances where a scheme has more than one administrator, including an additional voluntary contributions provider. The guidance includes the current views of TPR and the Financial Conduct Authority (FCA) where a scheme cannot connect all parts of the scheme on the same date.
The Pensions Dashboards Programme (PDP) has issued a Data Protection Impact Assessment (DPIA) about the processing of personal data by the Money and Pensions Service in accordance with its function to deliver the PDP, to build and run the central digital architecture, to connect pension providers and schemes, and to provide related services. This should provide reassurance for trustees who are considering the data protection aspects of their scheme’s dashboards processing activities. Trustees may wish to cross refer to the PDP’s document when preparing their own DPIA.
The Work and Pensions Committee has written to pensions minister, Torsten Bell, raising a number of questions about pensions dashboards – including whether dashboards users will ever be able to carry out transactions such as consolidating pension pots or making additional contributions.
With “late spring” fast approaching, we are wondering if the Pension Schemes Bill will shortly make an appearance. By way of reminder, we are expecting it to include legislation facilitating automatic small pot consolidation, a new value for money framework (driving DC consolidation), a requirement for occupational DC pension schemes to offer decumulation products, the expansion of collective defined contribution to allow for nonassociated multiemployer schemes, legislation around defined benefit consolidation, affirmation that The Pensions Ombudsman is a competent court, greater flexibility in relation to the Pension Protection Fund (PPF) levy and possibly even the groundwork that would allow the PPF to act as a consolidator of schemes that are unattractive to commercial consolidators.
Our labour and employment colleagues are hosting a webinar on 11 June 2025, exploring the key legal and practical issues to be aware of when managing small-scale redundancies, i.e. when collective redundancy consultation obligations are not triggered.