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 Pension Schemes Bill has had its third reading in the House of Lords. A few drafting amendments were made to the bill during its third reading, but otherwise the significant amendments are those that we noted in part one of last week's update. Possibly the most significant amendment made by the House of Lords has been the removal of the government’s power to mandate the way in which pension trustees invest defined contribution (DC) pension funds. It has been widely reported in the press that the government proposes countering opposition to mandation by introducing caps that would reflect the voluntary agreement reached under the Mansion House Accord (being a minimum 10% allocation to private markets across all main default funds in DC schemes by 2030, with at least 5% of the total going to UK private markets). The amendments made to the bill by the House of Lords will be considered by the House of Commons on 15 April.
In anticipation of the Pension Schemes Bill becoming law, The Pensions Regulator (TPR) has published guidance in relation to the Virgin Media remedy contained in the bill. TPR notes that trustees of schemes considering whether to take advantage of the Virgin Media remedy will normally first need to seek advice and information from their legal adviser, and that they may need advice and information from their actuary, as well as information from their administrator. Trustees may also need to discuss remediation with the sponsoring employer. TPR notes that trustees may give a formal instruction to start work to their actuary in advance of the bill becoming law. However, unless there is a pressing need to act more quickly (such as an imminent buyout project), where trustees have been taking an active watching brief on the issue, we think it would be reasonable for them to continue to do so for the time being and be ready to seek legal advice as soon as royal assent occurs.
The House of Lords has considered the reasons put forward by the House of Commons for rejecting amendments made to the National Insurance Contributions (Employer Pensions Contributions) Bill by the House of Lords (see part one of last week's update for those amendments). The House of Lords did not insist on their amendments, meaning that the bill has now been agreed. The bill imposes a cap of £2,000 on the amount of pension contributions that can be made (without being subject to national insurance contributions) as part of a salary sacrifice arrangement. This will come into force on 6 April 2029.
HM Revenue and Custom’s (HMRC’s) pension schemes newsletter 179 contains a reminder that from 6 April 2026, all scheme administrators must be a UK resident. As noted in our weekly update on 12 November 2025, this does not refer to your usual third-party provider of administration services. The “scheme administrator” in this context is the person who is registered on HMRC’s online platforms as the scheme administrator. This is usually one or more of the pension scheme’s trustees. If a scheme currently has an oversees person acting as the “scheme administrator”, they must remove themselves as scheme administrator (ensuring that one or more persons remain). If the overseas person is the only scheme administrator, they must first associate someone else who is a UK resident, before removing themselves. Trustees should check that they do not have a non-UK resident fulfilling the scheme administrator function for their scheme.
Following part one of its response to consultation on scheme improvements (access and protections) to the Local Government Pension Scheme (LGPS), the government has published regulations granting elected mayors and councillors in England access to the LGPS. The regulations come into force on 11 May 2026.
The Pensions Administration Standards Association (PASA) has published the final instalment of its trustee-administrator lifecycle guidance. The concluding section explores how relationships can be established, maintained and strengthened through open dialogue, proportionate governance and a focus on long-term outcomes. PASA plans to continue engaging with trustees, administrators and other industry stakeholders over the coming months to test, refine and build consensus around the guidance.
As reported in a previous update, the Pensions Dashboards Programme (PDP) is consulting on updated reporting standards. It has recently extended the deadline for responses to 30 April 2026.
The Financial Conduct Authority (FCA) is consulting on alterations to its rules to make it easier for firms to provide simplified forms of personalised advice to customers with straightforward needs. This should make the advice more accessible and affordable. The consultation also considers existing rules relating to financial advisers’ ongoing services. Comments are invited by 22 May 2026.
Pensions partner, Wendy Hunter, was delighted to be a guest speaker to discuss guided retirement as part of WTW’s Pensions Perspectives series of podcasts.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
