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 government has published a consultation on pension scheme trusteeship, governance and administration. It comprises 27 questions across the topics of good governance (including in relation to megafunds), raising standards for both professional and lay trustees, the use of a professional sole corporate trustee and the challenges with that type of model (such as the potential for conflicts of interest to arise), taking account of members’ views, as well as the introduction of minimum standards for and regulation of scheme administrators and integrated service providers. An interesting, if not unexpected, proposal is to introduce a statutory requirement that professional trustees must meet certain minimum accreditation standards. The Department for Work and Pensions (DWP) is also exploring whether to limit the term of office for a trustee to a scheme, and whether to limit the overall number of appointments that a professional trustee might have. The possibility of establishing a public trustee is also being considered, although there is no indication as to how such an office would be funded. The DWP website notes that consultation closes at 11:59 p.m. on 5 March 2026.
The Pensions Regulator (TPR) has published revised administration guidance that applies to all types of schemes. The guidance includes new elements, including: the importance of effective oversight by trustees, the need to broaden performance measurement to reflect the quality and accuracy of scheme administration (rather than pure time-based measurements) and guidance on IT system governance. The guidance follows TPR’s recent market oversight report, which we covered in a previous update.
The Financial Conduct Authority (FCA) has issued its “near-final” rules for the new regulatory framework for targeted support in pensions and retail investments. Targeted support will allow firms to provide suggestions to groups of consumers with common characteristics. The new rules are expected to take effect from April 2026, with firms able to apply for permission to provide targeted support from March 2026. The FCA has also published joint statements with the Financial Ombudsman Service (to clarify working practices in the event of future complaints about targeted support), and with the Information Commissioner’s Office (on how firms can communicate with consumers in the context of existing direct marketing rules). In Chapter 9, the FCA summarises the consultation feedback received from trustees on the support they would like to provide to members, with FCA comment around regulatory boundaries. The FCA recognises the “complex questions trustees are facing” and states its commitment to work collaboratively with regulatory partners and industry stakeholders to find practical solutions, although “many of these issues may ultimately fall to government to resolve”.
The FCA has published the ninth edition of its regulatory initiatives grid. The grid sets out a timeline for various initiatives of regulatory bodies, including TPR. The grid includes updated timings. Initiatives relating to pensions start on page 51 while multi-sector initiatives, some of which are relevant to the pensions landscape, start on page five. The grid indicates that the Pension Schemes Bill is still expected to receive royal assent during “spring” 2026. Regulations on release of surplus from defined benefit pension schemes are expected to be consulted on and published by the end of 2026, with TPR’s guidance to be consulted on and published by the end of 2027.
The Money and Pensions Service (MaPS) has issued an update report on pensions dashboards. This includes progress with connections, user testing (which has been “broadly positive” so far) and updates from government, regulators and the Pensions Dashboards Advisory Group.
Pensions UK has published its stewardship and voting guidelines 2026, with the aim of providing a framework for pension scheme trustees and their advisers to “drive responsible investment and influence positive corporate behaviour globally”.
Have you seen our festive pensions quiz? The deadline for entries is 5 p.m. on Friday 19 December.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
