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 Regulator (TPR) and the Financial Conduct Authority (FCA) have issued a joint consultation, consultation response and discussion paper on the new value for money (VFM) framework for defined contribution workplace pension schemes. The main changes since the previous proposals include a central VFM database, a requirement for VFM to be assessed against a wide commercial comparator group, a four-point rating system (red, amber, light green and dark green) and the inclusion of forward-looking investment performance metrics (as well as backward-looking metrics). Responses are requested by 8 March 2026. This work will inform regulations for trust-based schemes and FCA rules for contract-based schemes. It is intended that the first new VFM assessments will be required in 2028.
The Pensions Dashboards Programme (PDP) is seeking feedback on how to best support the delivery of private sector dashboards. Feedback is requested by 10 February 2026.
The Society of Pension Professionals (SPP) has published its response to the government’s technical consultation on the future of the Local Government Pension Scheme (LGPS). The SPP notes that the draft regulations address some of the concerns that the SPP had raised previously in relation to the government’s proposals for the LGPS. The SPP’s response makes some technical comments intended to assist with clarifying various provisions in the draft regulations. Meanwhile, the LGPS England and Wales Scheme Advisory Board has highlighted the risks of making changes at the same time across almost every aspect of the LGPS, leading to poor policy implementation, sub-optimal outcomes for administering authorities and the possibility of TPR or the Ministry of Housing, Communities and Local Government bringing enforcement action where requirements are inadvertently misunderstood. Some in the industry are starting to question the likelihood of the Pension Schemes Bill and associated LGPS regulations being in force by a key date of 1 April 2026.
The Pension Protection Fund (PPF) has published answers to some frequently asked questions in relation to the proposals contained in the Pension Schemes Bill that would enable the PPF to pay pre-97 indexation for members of schemes that provided mandatory increases in relation to pre-97 accrual.
In addition to the Pension Schemes Bill that is currently making its way through Parliament, which is expected to receive royal assent during the first half of 2026, there are other key developments to watch out for in the coming months.
On the legislative front, the pensions inheritance tax provisions in the Finance (No. 2) Bill, effective from April 2027, are making their way through Parliament, along with the bill that will give power to make regulations introducing a cap on salary sacrifice arrangements (intended to be effective from April 2029). HM Treasury is shortly expected to lay legislation before Parliament that will create a new specified activity of providing targeted support, and regulations extending collective defined contribution (CDC) to unconnected employers will come into force on 31 July 2026.
In case law, judgment is awaited in the case of Verity Trustees Limited v Katherine Wood and Others, which addresses more issues around the need for actuarial written confirmation in the case of amendments made to schemes that were formerly contracted out on a defined benefit basis. This judgment will be important for those schemes that are ineligible to take advantage of the Virgin Media remedy contained in the Pension Schemes Bill.
Consultations on various initiatives close during the first quarter of 2026, including consultations on (1) updating TPR’s CDC code of practice to extend it to unconnected employers (13 February), (2) pension scheme trusteeship, governance and administration (5 March), (3) VFM framework (8 March) and (4) proposed FCA rules and guidance for the regulation of Environmental, Social and Governance (ESG) ratings providers (31 March). A consultation is also expected on draft statutory guidance on the fiduciary duties of pension trustees. The chancellor ’s spring forecast will take place on 3 March 2026.
Under the General Code of Practice, schemes with year-end dates of 31 March or 5 April will be carrying out their first own risk assessments by 31 March 2026 or 5 April 2026 respectively.
Finally, 1 April 2026 is the deadline for the accelerated consolidation of LGPS (England and Wales) assets.
The Employment Rights Bill received royal assent on 18 December 2025, and is now an act of Parliament. It will make several significant changes to UK employment law and there will be a lot of work for employers to do to prepare for the changes. The good news is that not all the changes will come into force at once. Instead, they will come into force in stages over the next two years. Our At a Glance Guide provides more information, and Matthew Lewis and James Pike provide a high-level overview in this webinar recording. More detail can be found in our page of resources.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
