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 latest list of ministerial appointments confirms that Torsten Bell will retain his position as pensions minister. What would be your top priority if you were the pensions minister for a day? Our team shares some thoughts in our new video.
We included a link in last week's update to a discussion paper on the key elements of the defined contribution (DC) scaling up policy, which was introduced by the Pension Schemes Act 2026. From April 2030, all authorised master trusts and group personal pension schemes (GPPs) that are used for meeting automatic enrolment obligations will be required to have assets of at least £25 billion in a single main scale default arrangement (MSDA). Alternatively, a scheme with £10 billion of assets may be approved for transitional arrangements if it is on track to meet the £25 billion requirement by 2035. Assets held in an MSDA must be held under a common investment strategy (CIS). The asset value can also be made up of the collective assets of connected master trusts and GPPs. It cannot include assets from stakeholder schemes or single employer trusts. The scaling regulations will set out the parameters about the assets that can be included, excluded or adjusted in an MSDA. The paper says the intention is that schemes will only be connected where they sit in the same corporate group. Where a single provider has more than one multi-employer DC workplace scheme that will be subject to the scale requirements, it will be able to combine the assets in their master trusts and GPPs into an MSDA. This is subject to all assets in the shared MSDA being managed under a single CIS and meeting the requirements to be connected. The discussion paper focuses on how providers will be able to achieve the requirements in practice, how assets should be measured and seeks feedback before 11:59 p.m. on 7 September 2026.
The thorny topic of mandation seems to bob along the horizon. We noted last week that The Pensions Regulator (TPR) has published an analysis paper on asset allocation in occupational DC master trusts. Meanwhile, the Financial Conduct Authority (FCA) has published an analysis paper on asset allocation data of FCA regulated providers. TPR found that while around 60% of 25 master trusts respondents have some unlisted private market exposure, only 20% of master trusts invest more than 5% of their assets in unlisted private markets. The FCA found that of the eight contract-based multi-employer respondents, 4.1% of assets in default arrangements were invested in unlisted private markets, but that only 1.5% of assets were invested in UK unlisted private markets. The FCA said that the key findings would be useful in developing the value for money framework.
The Registered Pension Schemes (Provision of Information) (Miscellaneous Amendments) Regulations 2026 have been laid before Parliament and come into force on 6 April 2027. They amend existing legislation to include the information sharing requirements (between pension scheme administrators and personal representatives of deceased members) that will come into effect as a consequence of certain pension death benefits falling within the scope of inheritance tax from 6 April 2027.
The Pensions Dashboards Programme has published a progress report, which also contains updates from the Department for Work and Pensions (DWP), regulators and industry partners. The report confirms that connection plans are on track and includes the latest news on MoneyHelper dashboard user testing. The latest news will be discussed further at a webinar on 29 July at 11am.
The Pensions Ombudsman (TPO) is inviting stakeholders across the pensions industry to register for the annual (in person) stakeholder forum on Wednesday 16 September. TPO says that the session is designed with the aim of improving communication and achieving a better understanding of the needs and challenges of the pensions community, along with enhancing service.
The Pension Protection Fund (PPF) has published its annual report and accounts for the year ended 31 March 2026. As of 31 March 2026, the PPF had assets under management of £31.5 billion with £15.1 billion of reserves. The report includes a case study of a £60 million investment made in the Haweswater Aqueduct Resilience Programme, one of the largest UK infrastructure deals in recent years. The programme is designed to secure the long-term supply of clean water to 2.5 million people across Greater Manchester and Lancashire. The report also notes that around half of the PPF’s portfolio is invested in the UK, with 35% invested in private markets and 7% invested in UK productive finance.
As AI systems continue to be adopted at scale, they are increasingly performing tasks carried out by human employees – from drafting documents, to writing code and handling customer queries. Concerns have grown about the economic risks this shift may pose, including job displacement and the erosion of the income taxes generated by human labour. Pensions partner, Matthew Giles, and colleagues consider the potential for new taxes in this blog post.
We are delighted to welcome two new members to our pensions team this week. Amanda Small has joined as a partner and head of our Manchester pensions practice and Alison White, also based in Manchester, has joined us as a director.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
