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 guidance on manual reporting to the Money and Pensions Service (MaPS). Directly connected organisations that have not yet been able to implement daily reporting via an application programming interface need to undertake manual reporting from October 2026 (for September data). For more background, see our previous update.
The Collective Defined Contribution (CDC) regulations for unconnected multiple employers came into force on 31 July 2026. The Pensions Regulator (TPR) has issued new and updated CDC guidance, including how to approach the fit and proper persons requirement, as well as the promotion and marketing of multiemployer CDC schemes. The guidance should be read alongside the updated CDC code of practice.
The Society of Pensions Professionals (SPP) has issued a practical framework for the governance of artificial intelligence (AI) in the pensions industry. The framework is intended to complement existing regulatory expectations by “identifying the key questions trustees should ask, the controls they should expect to see and the governance arrangements that should underpin responsible AI adoption across the pensions ecosystem”. The paper highlights the opportunities presented by AI and the risks associated with poor management.
Scheme members are increasingly using AI to assist with complaints submitted through internal dispute resolution processes. The length of AI generated complaints and the language used in them is causing difficulties for pensions professionals and for ombudsman services, due to the time it takes to understand the basis of each complaint. In the world of employment, the use of AI is also causing headaches for HR professionals dealing with AI-expressed employee grievances. According to our firm’s Labour & Employment partner, David Whincup, AI tends to generate output in “a pseudo-legalistic and passive-aggressive tone, which cannot help but put the reader’s teeth on edge”. David suggests in his blog post how employers should work with the employee (rather than the “keyboard warrior”) to seek a resolution.
TPR has made some technical updates to its defined benefit (DB) superfunds guidance. The guidance focuses primarily on how trustees of a superfund pension scheme should approach managing the funding and governance risks associated with being a superfund. The guidance also contains important information for those setting up and running a superfund, including directors and senior managers. TPR says that it is considering separate guidance for trustees and employers who are considering alternative endgame options, including transfer to a superfund. TPR is applying this guidance in advance of the superfund regulatory regime, introduced by the Pension Schemes Act 2026, being in place. The Department for Work and Pensions (DWP) is expected to consult on draft legislation for the regime during Q1 of 2027. Final form legislation and a TPR code of practice is expected to be in place by October 2028. In the meantime, anyone considering setting up any alternative arrangements for endgame planning is asked to liaise with TPR.
The DWP has published statistics on workplace pension savings and participation trends from 2009 to 2025. The analysis shows that around 90% of employees in Great Britain who were eligible for automatic enrolment were saving into a workplace pension in 2025, while there was an overall workplace pension participation rate of all employees in Great Britain of around 82% in 2025 with 24.2 million employees saving into a workplace pension. In relation to accessing private pension savings, the analysis shows that 94% of the 12.9 million individuals in receipt of a private pension payment in 2025-2026 are in receipt of a DB pension or an annuity. However, when assessing private pensions accessed for the first time, the proportion receiving a defined contribution (DC) lump sum or other DC product has risen from 37% (280,000) in the 2016-2017 financial year to 49% (410,000) in the 2025 to 2026 financial year.
Our firm’s Employment & Labour senior practice development lawyer, Clare McNicholas, takes a look at a surprise consultation published by the Advisory, Conciliation and Arbitration Service (ACAS) on updates to its statutory Code of Practice on disciplinary and grievance procedures.
We are delighted to be shortlisted as one of only three firms in the “law firm of the year” category in the 2026 Local Authority Pension Funds (LAPF) Investment Awards, which recognises excellence in support and service to 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.
