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 Dashboards Programme (PDP) has issued a response to its consultation on proposals to update the reporting standards to implement routine daily reporting of data to the Money and Pensions Service (MaPS) via an application programming interface. The proposed implementation date of 30 November 2026 will be pushed back to 1 March 2027, in response to industry concerns that the original date is not universally achievable. However, directly connected organisations that have not been able to implement daily reporting will be required to undertake some manual reporting from Autumn 2026, to ensure that information is flowing through to MaPS and regulators at the earliest opportunity.
The Pensions Administration Standards Association (PASA) has issued guidance to support trustees, administrators and others with monitoring ongoing dashboards compliance across the core areas of data matching, pension information provision and connection performance. PASA has also issued a short note covering the treatment of survivor benefit indicators within dashboards value data, to support consistent interpretation across schemes and providers. Separately the Local Government Pension Scheme has issued an updated before and after connection guide for administering authorities.
In our update on 25 June 2025, we noted that HM Revenue & Customs (HMRC) had published a policy paper relating to the deduction of value added tax (VAT) by employers on the management of pension fund assets. Our update contained some background information generally in relation to the treatment of VAT and defined benefit (DB) occupational pension schemes. HMRC has now updated guidance in its internal tax manual to expand on the policy set out in the 2025 paper. Paragraph VIT44650 states that input tax incurred by an employer on services provided in relation to its funded occupational pension scheme will be the employer’s input tax. This input tax is considered an overhead, as it is directly linked to the employer’s business as a whole. HMRC says that it is therefore recoverable in full, subject to any partial exemption restrictions. This treatment is the same whether the costs incurred relate to administration or management of the scheme’s investments. However, the manual goes on to require that employers contract directly with a provider of fund management services (usually evidenced by an invoice) or, if the services are provided to the trustees, who are invoiced, the trustees must make a taxable charge to the employer for their services of running the scheme on the employer’s behalf. The employer will then be able to deduct input tax on this charge. Alternatively, a corporate trustee of an occupational pension scheme can VAT group with an employer, subject to certain conditions. DB trustees and employers may therefore wish to review how they currently deal with the deduction of VAT. In relation to defined contribution (DC) schemes, the manual notes that many investment and administration services will be exempt. Guidance on determining whether this applies in any specific case can be found in VATFIN5350.
The Pensions Regulator (TPR) has published a blog by executive director of market oversight, Ben Gunnee, in which the potential for further innovation in the DB landscape and TPR’s expectations of trustees are discussed. The blog focuses on a flexible apportionment arrangement that occurred in December 2025, that caused interest in the industry because it was not implemented as part of a wider corporate restructuring, but as a means of simply transferring a scheme to a different sponsor. The blog notes that the trustees of the scheme in question consulted TPR, and took appropriate advice. The circumstances were unusual and innovative and allowed the trustees to pay an immediate uplift to benefits, along with the potential to share ongoing surplus between the members and the new sponsor, rather than paying a premium to buyout benefits with an insurer. Pending consultation by the government on the use of flexible apportionment arrangements, TPR expects any other schemes looking at innovative endgame options to consult with TPR in the first instance.
In this LinkedIn post, Matthew Giles shares his thoughts on whether the imposition of a robot tax is on the cards for those in the pensions industry.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
