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 Dashboards Programme (PDP) has issued a blog on how pensions information is categorised and displayed on dashboards, depending on the results of the data-matching process and what view data is available. This categorisation is one of the most important features of user testing. Data for each pension scheme may appear as “confirmed” (where data matching is successful and data is available to view), “pending” (where data matching is successful but not all data is available to view), or “needs action” (where there is either a partial match or the scheme requires the user to make contact). Phase 2 of testing of the MoneyHelper dashboard started last week, and industry help is being sought to encourage members to volunteer for the testing process. Trustees and administrators should be prepared for dashboards-related queries as user testing is rolled out more widely. We remind trustees to review privacy notices and to consider carrying out a data protection impact assessment.
Trustees of schemes with a 31 March or 5 April year end are fast approaching the deadline for the scheme’s first own risk assessment (ORA). The ORA should be in writing and signed by the chair of trustees. Please contact us if you need any assistance or if you are concerned about meeting the deadline. Our general code resource hub contains useful information.
The Pensions Regulator (TPR) has published a press release commenting on key findings in its 2025 defined contribution (DC) scheme return analysis of decumulation products in DC schemes. TPR notes that over two-fifths of DC schemes still offer no decumulation products, and it urges smaller schemes to act or consolidate in savers’ interests. TPR says that 13.4 million members of occupational DC schemes are now offered drawdown at the point of retirement; 86% of the largest schemes offer members at least one retirement income option; in contrast, just 46% of small schemes offer members any decumulation product; 43% of all members – represented by 16% of schemes – can now access drawdown without leaving their schemes; and the shift towards in-scheme drawdown is largely driven by the growth of master trusts, which have the scale and governance to make it a reality.
In connection with the Pension Schemes Bill, the government has published a policy paper on DC scale and consolidation. This seeks to set out the government’s direction of travel post Pension Schemes Bill, before there is detailed consultation on regulations. The government says that the policy paper does not replace formal consultation; nor does it anticipate the final regulatory framework. The paper does, however, provide more explanation around the transition pathway (available to certain schemes that are unable to meet the £25 billion asset requirement by 2030) and the new entrant pathway. Alongside the policy paper, TPR has published a statement that explains what is meant by having a credible growth plan for those schemes that wish to pursue the transition pathway. TPR acknowledges that some smaller master trusts are being excluded from pitching for business because there is an assumption that the master trust will not meet the scale requirements by 2030. TPR says “While not every master trust will achieve scale of £25 billion by 2030 or 2035, employers and their advisers should not assume that all master trusts not yet at scale will be unable to meet the criteria. Our supporting analysis suggests there remains significant momentum and growth potential in the master trust sector as a whole.”
TPR has issued a report on the evolution of occupational defined benefit (DB) schemes, projecting how the DB landscape will look in 2035. TPR predicts that there will be a financially significant DB market with assets under management of £0.6 trillion to £0.7 trillion in real terms and with “space in the market for both insurers and superfunds to operate”. TPR encourages trustees to understand all options open to DB schemes.
Pensions partner Matthew Giles recently participated in a Society of Pension Professionals (SPP) interview on the current and potential uses of artificial intelligence in the pensions industry.
The latest batch of consultations flowing from the Employment Rights Act 2025 includes the much-anticipated consultation on the new threshold for triggering collective redundancy consultation obligations, along with a consultation concerning the protection against detriment to be afforded to workers when taking industrial action. In its latest insight, our Labour & Employment team highlights the key points to be aware of.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
