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 blog on the ongoing responsibilities of maintaining connection to the pensions dashboards ecosystem. PDP says “Whether you have connected directly or via a third-party, there are ongoing responsibilities to maintain your connection, keep your data accurate and ensure your systems remain secure. Understanding where these responsibilities sit, and how they are shared with any third parties you work with, will help you stay compliant and support the smooth running of dashboards for members.”
The Finance Act 2026 introduced a new requirement for “tax advisers” to register with HM Revenue and Customs (HMRC). HMRC has now updated its guidance on registration as a tax adviser. This includes an interactive tool. The definition of tax adviser is wide. It captures an organisation that, in the course of a business carried on by it, assists other persons with their tax affairs, including providing assistance with any document that is likely to be relied on by HMRC to determine the other person’s tax position (such as a tax return). Schedule 20 provides certain exemptions from the obligation to register as a tax adviser. HMRC reassured the pensions industry in Newsletter 176 that providers of pension scheme administration services (referred to as scheme practitioners) would be exempt from the requirements. Schedule 20 does not, however, specifically carve out those providing pension scheme administration services from the obligation to register. Instead, pension scheme administrators are likely to have to rely on exemption (h) (where the adviser interacts with HMRC in order to comply with an obligation of the adviser under any enactment, including the Finance Act 2026), and/or exemption (i) (where the adviser interacts with HMRC in response to a request for information from HMRC). Unfortunately, the latest guidance provides no further clarification in relation to pension scheme administrators.
Various consultations are closing over the next few weeks, including:
Consultation on draft regulations relating to the release of surplus to the employer: 11:59 p.m. on 2 September 2026
Consultation on draft legislation amending the Finance Act 2004 to make surplus release to members an authorised payment: 7 September 2026
Discussion paper on scaling up defined contribution schemes: 11:59 p.m. on 7 September 2026
Consultation on changes to the general levy for the period April 2027 to March 2030: Midday on 8 September 2026
Consultation on the value for money framework, draft regulations and draft Financial Conduct Authority (FCA) rules: 11:59 p.m. on 15 September 2026
Consultation on draft secondary legislation to provide transitional tax provisions in connection with the increase in the normal minimum pension age from age 55 to age 57 from 6 April 2028: 11:59 p.m. 28 September 2026
Did you see the partial eclipse on 12 August? From eclipses to pensions, there is more on the horizon: watch out for our Autumn Hot Topics in Pensions, which has a cosmic theme.
We are pleased to be shortlisted for Lawyer of the Year in the LGC (Local Government Chronicle) Investment Awards 2026, which recognises excellent service and innovation in the Local Government Pension Scheme.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
