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 normal minimum pension age (NMPA) is increasing from age 55 to age 57 on 6 April 2028. HM Revenue and Customs (HMRC) has published draft legislation for consultation, which HMRC intends will implement transitional arrangements for individuals who are aged 55 or 56 immediately before the NMPA increase and who may already have become entitled to pension benefits or may already have taken steps to access those benefits. These provisions broadly mirror the transitional provisions that were put in place when the NMPA increased from age 50 to age 55 in April 2010, although they have been expanded to take account of some of the increased flexibilities for accessing pensions that were introduced in 2015. The consultation notes that without further provision, payments made after 5 April 2028 could potentially fail to satisfy conditions linked to the NMPA, despite the individual having satisfied the rules in force prior to the increase. Consultation closes at 1:59 p.m. on 28 September 2026.
HMRC has published Newsletter 183. This includes a reminder that the “Pension schemes online” service will be closing in April 2027 and that all schemes still using that platform should migrate over onto the new “Managing a pension scheme” service by the end of this calendar year. Our blog post provides more information. Also worth noting is that the process for contacting HMRC for pension-related enquiries is changing. Going forward, there will be an interactive guidance tool for use (rather than an email address).
HMRC’s Newsletter 183 also contains an update on the payment of inheritance tax in connection with pension death benefits from 6 April 2027. There will be further legislation later in 2026 to complement information sharing regulations that amend existing legislation to include the information sharing requirements between pension scheme administrators and personal representatives of deceased members. Also, a further technical note is expected later in the summer, which will contain information on withholding and payment notices, and scenarios to illustrate the new inheritance tax on pensions process, as well as addressing common queries raised by industry stakeholders.
The Pensions Administration Standards Association (PASA) has published interim guidance to help administrators, providers and service centres when replying to member questions about pensions dashboards. It sets out frequently asked questions and responses that provide simple, factual explanations while managing member expectations about dashboards functions. The interim guidance will be updated as more information becomes available.
In our weekly update on 16 July 2026, we highlighted several documents that the government has published in connection with measures contained in the Pension Schemes Act 2026, including a consultation on value for money (VFM) draft regulations and Financial Conduct Authority rules. The deadline for responding to the consultation has now been extended from 11:59 p.m. on 1 September 2026, to 11:59 p.m. on 15 September 2026.
Labour and employment partner David Whincup looks at proposed changes to the Acas code of practice in his latest blog post. The proposals would effectively make mediation the default start point for tackling workplace disputes and employees would be able to rely less on content generated by artificial intelligence (AI).
Natasha Maric, director in our Intellectual Property & Technology team, considers areas that deserve particular attention when reviewing and negotiating AI contracts in order to protect commercial interests and to maximise the value of the AI investment.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
