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 Financial Reporting Council (FRC) has published technical guidance to assist actuaries who are asked to provide retrospective confirmation under sections 100 and 101 of the Pension Schemes Bill, which address the validity of certain alterations to occupational pension schemes that were contracted-out on a salary related basis. We have referred to these clauses as the “Virgin Media remedy” in previous updates and summarised the remedy in our 3 September 2025 update. The FRC guidance is subject to change as the bill progresses through Parliament. The guidance is pragmatic and considers many different examples of potential scenarios that the actuary might face. It is intended to help actuaries consider whether they can provide retrospective confirmation “in a proportionate manner”, and to promote consistency across the industry. It also notes professional and ethical considerations for actuaries.
31 January is the deadline for submitting event reports and HM Revenue and Customs (HMRC) scheme returns in respect of the 2024/2025 tax year. These documents must be submitted on HMRC’s new platform called Managing Pension Schemes (MPS) service. It is no longer possible to submit event reports via the Pension Schemes Online service. While a pension scheme return will only be required if your scheme has already been migrated over onto the new MPS service (see our weekly update of 1 April 2025), the requirement to submit an event report is not dependent on the scheme being on the MPS service. It must, however, be submitted via the MPS service. If you need to submit an event report and your scheme is not yet on the MPS service, you should progress the migration process (although that is likely to extend beyond 31 January) in order to minimise the level of penalties that will apply in respect of late filing. See our weekly updates of 12 November 2025, 5 March 2025, 28 January 2025, 11 December 2024, 30 October 2024, 25 September 2024, 13 August 2024 and 1 May 2024 for more links and information on the migration process.
The Pensions Regulator (TPR) has issued a paper for trustees of occupational pension schemes, giving an overview of the new value for money (VFM) proposals for defined contribution (DC) schemes. The paper will be particularly useful in helping trustees get up to speed with this important development if they have not engaged with it so far. TPR encourages trustees to respond to the joint consultation, which closes on 8 March. The consultation will help to shape the Department for Work and Pensions’ (DWP) regulations under the Pension Schemes Bill. TPR explains that “all master trusts and the majority of single employer DC schemes” would be in scope, regardless of size.
The Pensions Dashboards Programme (PDP) has published a blog on data preparation for pensions dashboards, discussing why high-quality data and a robust data matching approach are important, what actions need to be taken and where to find guidance and support.
The Pensions Administration Standards Association (PASA) has published part two of its three part guidance on delivering effective digital transformation.
Fiduciary duties are proving a hot topic. Colleagues in our International Dispute Resolution team have produced a publication on fiduciary duties under English law in a commercial context. Meanwhile, Torsten Bell has confirmed in a written answer on 22 January 2026 the government’s intention to produce guidance on fiduciary duties for pension trustees. The pensions minister said that the guidance to be published “will also explore how trustees may consider members’ views, provided this remains consistent with investing in members’ best interests and will reaffirm that trustees should take account of all financially material matters, where appropriate in their investment decision making”. The first stage will be an industry roundtable to gather views and technical expertise.
Two pensions-related bills continue their progress through Parliament. First, the Pension Schemes Bill continues to be scrutinised by the House of Lords committee. There was much discussion in the 22 January and 26 January sessions around Clause 40 of the bill and in particular the government’s reserve power to mandate asset allocation, without reaching any conclusion. The committee was scheduled to finish its scrutiny on 26 January, but a further session has been scheduled for 3 February. The second bill making its way through Parliament makes provision from April 2029 for regulations to introduce a cap on pension contributions made by way of salary sacrifice that are exempt from national insurance contributions. This has now had its third reading in the House of Commons (unamended) and first reading in the House of Lords. It will have its second reading in the House of Lords, when it is debated more fully by that house, on 4 February 2026.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
