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 Department for Work and Pensions (DWP) has issued a consultation on amendments to the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021. The consultation proposes amendments to address “operational challenges that, while well‑intentioned, may have at times created unnecessary friction for legitimate transfers”. The consultation notes the high instance of member referrals for safeguarding appointments triggered solely by amber flags on overseas investments and acknowledges concerns that trustees cannot exercise their experienced judgement in straightforward cases where the risk of a scam is demonstrably low. The consultation also sets out targeted measures to address the risk of fraud within small self-administered schemes (SASS). The consultation runs until 21 July 2026.
HM Revenue and Customs (HMRC) has issued a technical consultation on draft regulations impacting guaranteed minimum pension (GMP) conversion. Currently, when pension schemes equalise GMPs using the DWP’s statutory conversion method, some protections could be lost. The effect of this is that certain deferred members could lose their deferred member carve-out protection so that additional monitoring and communication of the value of their converted benefits for their annual allowance is required and means that they could face unexpected annual allowance tax charges. The draft regulations are intended to maintain those deferred carve-out protections so that any alteration in benefit to implement GMP conversion does not form part of the member’s annual allowance. Consultation closes at 11:59 p.m. on 13 July 2026.
The government has published its outcome of consultation on chapter nine of the public policy consultation on retirement collective defined contribution (CDC) pension schemes, which was launched on 23 October 2025. The consultation considered amendments to the legislation that would permit the bulk transfer without member consent of occupational defined contribution (DC) benefits without guarantees to authorised CDC schemes. The government has confirmed that it intends to proceed with this proposal, which will include transfers to CDC sections as well as whole schemes, along with unconnected multiple employer schemes. The logic is that the receiving CDC scheme or section “has passed a robust authorisation process and remains subject to regulatory supervision on an ongoing basis, which means that the risk of member detriment is significantly reduced”. The changes being introduced will not, however, apply in relation to the transfer of members into a retirement CDC scheme as part of a default retirement solution. Member consent will be required in those circumstances. Regulations have been laid before parliament and are due to come into force on 31 July 2026. The regulations will amend regulation 12 of the Occupational Pension Schemes (Preservation of Benefit) Regulations 1991. Guidance first published in 2018 has also been amended to reflect the change.
The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2026 have been laid before Parliament, and make consequential amendments to legislation in relation to the abolition of the lifetime allowance and lifetime allowance charge. Some of the provisions come into force for events occurring on or after 29 June 2026, while the remainder have effect for the tax year 2024-2025 onwards.
Pensions UK has issued an update to its retirement living standards, estimating how much income is needed to maintain a minimum, moderate and comfortable lifestyle in retirement. In a press release, Pensions UK says that “the nation is not saving enough” with only around 23% expected to reach a moderate lifestyle.
The Pensions Policy Institute (PPI) has published a report on the strengths and limitations of megafunds, the challenges faced by the UK and what we can learn from international experience. The report highlights that a move to consolidate UK pension schemes into megafunds will not automatically lead to higher investment returns. Other challenges include member experience – it is noted that the larger Australian superfunds are “finding it difficult to service members effectively”. The PPI has also published reports on Designing guided retirement solutions: meeting member needs and Unlocking DB surpluses: balancing risks and rewards.
The Money and Pensions Service (MaPS) is inviting applications to join a private sector dashboards working group. Membership will be drawn from organisations planning to operate a private sector dashboard and technology suppliers. It is not yet known when private sector dashboards will be able to operate.
In our #how2dopensions quick guide, we explore the risks and opportunities of using artificial intelligence (AI) to take trustee meeting minutes and notes, and offer some practical tips.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
