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) has issued an overview of the proposed new value for money (VFM) framework to help trustees understand the latest consultation and draft regulations and prepare for implementation. TPR summarises the latest proposals from the Department for Work and Pensions (DWP)/Financial Conduct Authority (FCA), including the phased introduction of VFM, which will cover master trusts and larger schemes first. The DWP/FCA consultation closes on 15 September 2026. The overview includes a handy flowchart for assessing which defined contribution (DC) arrangements are in scope of the requirements (based on the consultation). TPR suggests the preparations that trustees can take now towards VFM compliance.
TPR has also issued details of its proposed digital service that will allow schemes to submit data, access comparator data for assessments and report VFM outcomes for public disclosure. Schemes will be required to engage with the service throughout the year, which will require initial implementation activity and ongoing operational resource. Data submitted via the service will be made available to TPR and the FCA for monitoring and enforcement purposes.
TPR has started to populate its webpage dedicated to the Pension Schemes Act 2026. The webpage contains sections with links to guidance and other useful documents, along with a timeline of expected developments and is intended to serve as a central resource as implementation of the act progresses.
The government has now published explanatory notes to the Pension Schemes Act 2026. They run to a total of 106 pages and provide detailed commentary on the act’s provisions. The notes also include a table that sets out how various clauses in the bill progressed through Parliament, along with a table citing the Hansard references when various parts of the bill were discussed in Parliament.
And now for something a little different, for those sports fans among you. Wayne Barnes is a partner in our Government Investigations & White Collar Practice. He is also a former international rugby union referee and has presided over more international rugby matches than anyone else in history, including the 2023 Rugby World Cup Final. In this podcast, Wayne discusses with partner Tom Firestone the parallels between rugby refereeing and legal practice, including why referees and lawyers face many of the same practical and ethical dilemmas, from decision-making under pressure to the importance of trust, communication and consistency.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
