Pensions Weekly Update: Part Two

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Here is part two of 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 Department for Work and Pensions (DWP) has published a response to consultation on draft regulations that extend collective defined contribution (CDC) provision to unconnected multi-employer schemes (UMESs). A number of technical amendments were made following consultation, and the regulations have now been laid before Parliament. The DWP intends to bring the legislation, and an updated code of practice into force on 31 July 2026.
The DWP has issued a consultation paper on retirement CDC schemes. These will be a new type of CDC scheme for pensioner members, and there are specific challenges associated with the absence of ongoing contributions. These schemes are expected to feature in default pension benefit solutions under new guided retirement duties to be introduced under the current Pension Schemes Bill. The new type of scheme would operate as a section within a UMES or a master trust. Schemes would need specific authorisation from The Pensions Regulator (TPR) to operate as a retirement CDC scheme. Consultation closes at 11:59 p.m. on 4 December 2025.
Dominic Harris reports on The Pensions Ombudsman’s “excellent start” to the financial year in a recent blog post, updating the industry on its successful operating model review programme.
The government has published a progress update and next steps in relation to its regulation action plan. The regulation action plan is the government’s vision for how it will “re-energise the regulatory system, so that it not only provides critical safeguards and protects consumers and competition, but also supports investment and innovation, increasing productivity and driving economic growth”. As part of its next steps, the government has launched a business questionnaire as a chance for businesses, investors, representative organisations and charities to tell it which regulations and regulators are imposing the most burden. The questionnaire closes at 11:59 p.m. on 16 December 2025.
Our Labour & Employment team’s latest Quarterly Board Briefing includes a tracker that aims to provide boards with a guide to key upcoming legal changes, including critical dates, suggested actions and an assessment of any risk/opportunities arising. The Spotlight section at the end of the document includes additional notes for legal and HR teams on significant hot topics. In this quarter’s edition, the focus is on “Tightening the Belt: Alternatives to Redundancy”.
If you missed part one of our weekly update you can read it here.