Pensions Weekly Update – 13 August 2025

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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.

Companies House has updated its timeline for introducing certain requirements of the Economic Crime and Corporate Transparency Act 2023 (ECCTA). From 18 November 2025, directors and persons with significant control (PSCs) of companies incorporated in England and Wales will be required to verify their identity before the company can submit its annual confirmation statement. This will be relevant for trustee boards that operate through a corporate trustee. The verification process offers three options, but the simplest and quickest method is to use a smart phone and passport. Following the verification process, a unique code will appear on screen, which directors should take note of. This will need to be included in the company’s confirmation statement. It is still possible to undertake voluntary identity verification in advance of 18 November, which we recommend, in order to avoid any last-minute glitches when a confirmation statement is due.
The Taskforce on Nature-related Financial Disclosures (TNFD) has produced a discussion paper that explores the practical challenges financial institutions face in identifying, assessing and disclosing nature-related dependencies and impacts at the portfolio level. The TNFD invites feedback by 3 November 2025 on metric priorities, methodological approaches and practical data solutions to inform future guidance.
The government has published its response to consultation on improving the effectiveness of the money laundering regulations. The response includes the confirmation of a de minimis for trusts that are not liable to pay certain specified taxes but are required to register on the Trust Registration Service (TRS). Subject to certain conditions, the de minimis will exempt from registration UK trusts that hold assets of less than £10,000 and that do not have more than £5,000 in income per annum or more than £2,000 of “appreciable” non-financial assets. Registered pension schemes are exempt from registration on the TRS, but there may be some connected instances where registration is required. For example, a trust set up to hold a death benefit paid by a registered pension scheme in respect of a child is not specifically included in the list of exemptions set out in the money laundering regulations, so take advice if you are considering establishing one. A date for implementing the de minimis, which will not be retrospective, has not yet been set.
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