Pensions Weekly Update – 6 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 Pensions Ombudsman (TPO) has published its corporate strategy 2025-2028 and corporate plan 2025-2026, setting out its vision for the organisation as it tackles unprecedented demand for its services. TPO’s plans include reviewing and improving its application process to lessen the chances of invalid applications. TPO will work closely with the pensions industry to provide information and guidance to inform administrative decision making and promote good practice dispute resolution. TPO also plans to update its factsheet on redress for nonfinancial injustice, which was last updated in 2018.
The Pensions Administration Standards Association (PASA) has issued new guidance for trustees and pension providers on improving data security and governance. The guidance covers issues such as cyber resilience, third-party oversight, secure communications and responsible use of artificial intelligence (AI).
The Pension Protection Fund (PPF) has sent notices to scheme trustees in respect of the 2025-2026 levy year confirming that levy invoicing will be suspended pending Parliament’s consideration this autumn of clauses relating to the PPF levy in the Pension Schemes Bill. The PPF says “Mean scores will be published as normal in due course, but we are putting invoicing on hold until we’ve concluded our decision making. Doing so maintains the possibility of moving to a zero levy for conventional schemes for 2025/26.” A further update is expected in the autumn.
Mark Hill, climate and sustainability lead at The Pensions Regulator (TPR) has published a blog post on managing systemic risk, with a focus on investment governance and how consideration of climate change fits with trustees’ fiduciary duties. The blog post encourages trustees to engage with the Taskforce on Nature-related Financial Disclosures (TNFD) framework, as well as inviting trustees to submit evidence by 1 September to TPR that could be used to assist an industry working group to develop thinking around a practical approach to transition planning for occupational pension schemes. Three trustee action points from Mark Hill are to (1) engage with the government’s consultation on transition plans and TPR’s call for evidence, (2) explore the TNFD framework and (3) use the trustee toolkit to build environmental, social and governance (ESG) knowledge and confidence among the trustee board.
TPR’s recent report and accounts confirmed that good progress has been made towards the government’s future consultation on trusteeship and the broader regulatory framework. This consultation is expected in the summer and TPR has made a bid for “a Pension Reform Bill in the next parliamentary session.” We await the consultation with interest.
HMRC has published Pension Schemes Newsletter 171. It contains a reminder that responses are invited by 15 September to its technical consultation on draft legislation introducing an inheritance tax charge on certain types of pension pots. For more information on this, please see our weekly update from 23 July 2025. Newsletter 171 also contains more information about the Managing a Pension Scheme service, winding up and pension flexibility statistics.
Our colleagues in the Restructuring & Insolvency team have produced this roundup of restructuring news, which you might find interesting, including further clarification around who constitutes a secured creditor.