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.
Following on from its technical note on inheritance tax, HM Revenue and Customs (HMRC) has published a technical consultation on draft information sharing regulations. These relate to changes in the Finance Act 2026 that will bring unused pension benefits and death benefits into a deceased person’s estate for inheritance tax purposes. The draft regulations amend the Registered Pension Schemes (Provision of Information) Regulations 2026. They set out how information will be shared between pension scheme administrators and personal representatives of deceased members, and with beneficiaries and HMRC, in order to ensure compliance with the requirements relating to inheritance tax on unused pension pots. The measures will apply in respect of deaths on and after 6 April 2027. There is a very short consultation window running until 11:59 p.m. on 11 June 2026.
The Pensions Regulator (TPR) has launched a regulatory initiative to assess how defined benefit and hybrid schemes are preparing their dashboards data, with a particular focus on value data. This builds on previous regulatory interventions, which highlighted that many schemes were more focused on data matching than value data. This work will help inform discussions on the timing of the launch of the MoneyHelper dashboard.
The second pension commission has issued its independent, interim report Pensions 2050: Evidence and Future Priorities. The report considers the economic, demographical and societal changes since the first pension commission was appointed in 2002. Among the conclusions, the commission notes that private pension saving is inadequate, with around four in 10 people undersaving. The commission concludes that “responsibility for overcoming these challenges rests with the same three actors as it did 20 years ago: the state, employers, and individuals”. The commission invites views to inform its final recommendations that are due to be made to the government in Spring 2027.
The Pension Schemes Act 2026 introduces what has been colloquially referred to as the “Virgin Media remedy” – an opportunity to apply a retrospective fix where an alteration purporting to have been made to the rules of a scheme formerly contracted-out on the reference scheme test basis did not comply with the necessary legislative formalities (or there is no evidence to confirm compliance). The act provides that such an alteration is a “potentially remediable alteration” in certain circumstances, and if certain conditions are met. An actuary can now furnish retrospective actuarial confirmation if they are satisfied that the reference scheme test continued to be met following the historic amendment. This will help in relation to schemes that met the reference scheme test during the relevant period, but which do not now have a full set of written actuarial confirmations. Consideration should now be given to next steps, with legal advice.
Our full publication summarising the contents of the Pension Schemes Act 2026 and what is next, along with a timeline of expected developments, is now available. If you are short on time, our short form publication summarises the key measures.
While the timeline of expected developments flowing from the Pension Schemes Act 2026 extends to 2032 and beyond, watch out for some pensions developments that are expected during the next six months, including:
A consultation around draft guidance on trustees’ fiduciary duties – In December 2025, the pensions minister, Torsten Bell, said that this would be published in the first few months of 2026.
A consultation on enhancing transfer requirements – Torsten Bell confirmed in a written statement that the government would consult in the coming months on its “work to strengthen the transfer process with enhanced protections”.
The decision in Verity Trustees v Wood – This is expected before the summer and might provide further clarification in relation to questions left unanswered by the Virgin Media remedy in the Pension Schemes Act 2026.
A consultation on secondary regulations for the value for money framework – This Department for Work and Pensions’ consultation is expected by the end of June, alongside a final consultation by the Financial Conduct Authority (FCA), to ensure alignment.
A consultation on changes to the pension charge cap – Ensuring it does not disincentivise investments that may provide higher returns for consumers despite having higher performance fees. This FCA consultation is expected before the end of June 2026.
Consultations on regulations for guided retirement and superfunds – These are expected during summer 2026.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
