Pensions Weekly Update – 27 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.

The Information Commissioner’s Office (ICO) is consulting on draft guidance for organisations handling data protection complaints. This draft guidance precedes the introduction of a new right, under the Data (Use and Access) Act 2025, which will enable individuals to complain to “controllers” (including pension scheme trustees) if they consider that there has been a breach of data protection legislation. When the relevant provisions of the act come into force, trustees will be required to have measures in place to facilitate the making of such complaints. The draft guidance provides more information about the ICO’s expectations regarding those measures and indicates that trustees will have to adopt new processes to enable individuals to complain, as well as to ensure that complaints are responded to within the required timeframes. The ICO also recommends that a written complaints procedure be adopted. In due course, we anticipate that pension scheme privacy notices will also need to be updated to refer to this new right.
The Pensions Dashboards Programme (PDP) has issued a short video on dashboards connection progress. Hundreds of pension providers and schemes are now connected to the dashboards ecosystem – meaning that over 40 million workplace and private pensions records are now connected.
A joint podcast has been issued from Patrick Coyne, Interim Director of Pensions Reform at The Pensions Regulator (TPR), and Nike Trost, the Financial Conduct Authority’s (FCA) Head of Department – Asset Management and Pensions Policy. Patrick and Nike discuss how trustees should develop a deeper understanding of the different needs and profiles of their scheme membership to maximise the impact of guided retirement (or default pension benefit solutions). The discussion includes how the FCA’s targeted support proposals complement guided retirement, which Nike says “in a year or a couple of years” will lead to “an entirely different retirement offering” for defined contribution members. As mentioned in a previous newsletter, the FCA’s consultation on targeted support runs until 29 August 2025.
The Society of Pension Professionals (SPP) has published a paper called Saving Retirement: Who is at Risk and Why?. This includes suggestions for the new Pensions Commission on what it should consider and the benefits that the commission’s recommendations to government could help to deliver, along with examples of the tangible actions that the commission could recommend. The paper notes the importance of having a common definition of retirement “adequacy” that is used by policy makers, industry and employers alike. The SPP has also published a paper called Diversity, Equity and Inclusion: Neurodiversity. This looks at the benefits of creating an inclusive industry and makes some suggestions regarding the accommodations that could be made when relaying pensions information to members, along with suggestions for accommodations that might help neurodiverse individuals working within the industry.
HM Revenue and Customs (HMRC) has published pension schemes newsletter 172. This includes information about a new mandatory deadline of 6 July 2027 for active and deferred members affected by the public service pensions remedy. HMRC also says that it is seeking volunteers to test the new authenticated look up service that allows users to view a member’s lifetime allowance protections and enhancements.
Look out for our autumn Hot Topics in Pensions next week. Our action-packed edition will help you plan your agendas for the remainder of 2025.
We are delighted to be shortlisted for Lawyer of the Year at the LGC Investment Awards, the second shortlisting in as many weeks for excellent service and support to the Local Government Pension Scheme.