Pensions Weekly Update – 19 November 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.

Pat McFadden, Secretary of State for Work and Pensions, announced in the House of Commons that the government will revisit the decision taken in response to the parliamentary and health service ombudsman’s investigation into women's state pension age communications and associated issues. This follows further evidence cited as part of the legal challenge brought by the Women Against State Pension Inequality (WASPI) group. However, Mr McFadden said that “retaking this decision should not be taken as an indication that government will necessarily decide that they should award financial redress”.
The Pension Protection Fund (PPF) has published the consultation documents on its 2026/2027 levy. Subject to clauses relating to the PPF levy in the the Pension Schemes Bill progressing as planned, the PPF is proposing a levy of zero for 2026/2027 in respect of conventional schemes. The PPF says that it intends to continue to charge an Alternative Covenant Schemes (ACS) levy, reflecting that those schemes (such as superfunds) pose different risks to conventional schemes. The PPF has proposed refinements intended to further improve the ACS levy for next year, and proposes a wider review of the ACS levy methodology in the medium-term to inform how the PPF might need to further adapt its approach to reflect market developments.
The Society of Pension Professionals (SPP) has published two new papers on pre-1997 indexation and defined benefit (DB) surplus release. The first paper examines issues relating to pre-1997 indexation in DB pension schemes including the costs of protection, scheme member perspectives, trustee duties and considerations for employers. The second paper explores what constitutes a surplus, when releasing surplus may and may not be appropriate, the benefits and risks for members and employers, investment and governance issues and the wider consequences for the DB pensions landscape.
Our latest UK restructuring round up might be of interest.

If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.