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 press release reminding trustees and pension providers that the legal deadline for connecting schemes to the dashboards ecosystem is less than a year away. We understand that The Pensions Regulator (TPR) will soon contact schemes that have missed their connect-by date to inform them of compliance risks and to urge them to take action. TPR will also contact schemes that have connected successfully, to acknowledge their connection and to inform them of their ongoing duties. Separately, TPR is hosting a dashboards webinar on 3 December at 2:30 p.m. – this will include a live Q&A session.
- The Pensions Administration Standards Association (PASA) has issued guidance on the use of artificial intelligence (AI) in pensions administration, encouraging industry to “embrace the opportunity with caution”. The guidance covers the importance of maintaining high-quality data, provides practical examples of the use of AI by administrators and sets out key risk management considerations for trustees.
- HMRC has published Pension Scheme Newsletter 174. This includes information for schemes that wind up. It confirms that a pension scheme must still be migrated over onto the managing pension schemes service to report the windup on the event report. If the scheme was open during the 2025 to 2026 tax year, once an event report has been submitted, it will be necessary to file a pension scheme return for 2025 to 2026. This return will be due within three months of the notice being issued. The newsletter also contains a reminder of the rules around returning tax free lump sums, which we summarised in a previous weekly update.
- The Financial Reporting Council (FRC) has published guidance to assist with reporting against the UK Stewardship Code 2026, which will be in force from 1 January 2026. The FRC says that the guidance is optional and not prescriptive. It offers suggestions for the types of information that organisations may wish to include in their reporting to help explain their approach to stewardship. The FRC says that the guidance reflects the flexible nature of the code, which recognises that organisations differ in size, structure and investment strategy, and therefore exercise stewardship in different ways.
- A draft order has been laid before Parliament that will result in the provision of environmental, social and governance (ESG) ratings becoming a regulated activity within the meaning of the Financial Services and Markets Act 2000.
- Following the Autumn Budget 2024, the government established a social impact investment advisory group to assist with establishing a social impact investment vehicle. The advisory group was tasked with providing recommendations on ways to effectively mobilise social impact capital, and to provide views on existing work across government on impact capital. The group has now published its final report and recommendations, which the government has said it will consider.
- In line with its implementation roadmap, the government has started to issue consultations in relation to some of the reforms contained in the Employment Rights Bill. The first four consultations cover enhanced dismissal protections for pregnant women and new mothers, the right of trade unions to access workplaces, the duty to inform workers of their right to join a trade union, and bereavement leave, including pregnancy loss. This publication by our Labour & Employment colleagues provides more information.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
