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 Department for Work and Pensions (DWP) has published two consultations relating to guaranteed minimum pensions (GMPs). The first consultation seeks views on the proposed continuation of 3.25% per annum as the rate of revaluation applied to fixed rate revaluation of GMPs for early leavers. It is proposed that this rate would apply to contracted-out members who leave pensionable service in the period 6 April 2027 to 5 April 2032. The second consultation builds on the Pension Schemes (Conversion of Guaranteed Minimum Pensions) Act 2022 (2022 Act), which is not yet in force. The consultation seeks views on proposed draft regulations that are intended, in particular, to help those pensions schemes that plan to use the conversion methodology to fulfil their obligation to equalise for the effect of GMPs. By way of recap, the 2022 Act introduced three key measures:
It clarifies that the existing conversion legislation in the Pension Schemes Act 1993 applies to survivors and provides for a power to set out in regulations the conditions that must be met in relation to survivors’ benefits.
It allows the DWP to set out in regulations what trustees must do and who they must ask consent from if the sponsoring employer at the time the GMPs were accrued no longer exists or there are multiple employers.
It removes the requirement to notify HM Revenue and Customs (HMRC) of the conversion exercise.
The draft regulations pick up on the first two elements, and also include a new option for the certification of actuarial equivalence when the benefits of only one individual member are being converted at a time. The draft regulations, once in force, would only apply to GMP conversions undertaken after the regulations come into effect. Both consultations close on 29 October 2026.
The MoneyHelper dashboard is expected to be available to the general public during the 2027/28 tax year. The pensions industry anticipates a high level of member interest, which could lead to changes in member behaviour. Trustees and administrators may experience a surge in member enquiries in the initial weeks, followed by an increase in transaction activity, such as transfer requests. The Pensions Administration Standards Association (PASA) has issued a toolkit, outlining the internal reporting that may be useful for schemes to assess whether emerging trends require further action. PASA encourages trustees to adopt a consistent approach to reporting, so that industry trends can also be explored.
PASA has published new guided retirement operational readiness guidance. This focuses on the practical questions that schemes should be asking to assess their readiness for guided retirement, with implementation expected to commence in 2029. The guidance also includes a readiness checklist. David Fairs, chair of PASA, says “The additional implementation time for guided retirement is welcome, but it shouldn’t be confused with a reason to wait. Administration needs to be part of this conversation from the outset. Decisions about default pensions and member journeys have consequences for systems, data, people, processes and ultimately the experience members receive. There’s an important balance to strike. The industry shouldn’t build final solutions before the requirements are sufficiently clear, but neither should it wait to understand its capabilities and the scale of change which may be needed. Starting readiness work now will put schemes in a much stronger position as the framework develops.”
The 2026 Pay Your Pension Some Attention campaign launched last week, with record breaking vegetables and a message to encourage workers to grow their pension.
In the first episode of our AI Perspectives video series, international affairs advisor, Matthew Kirk, speaks with partner, Tanvi Mehta Krensel about the role of in-house counsel in evaluating, deploying and governing AI across multinational organisations. Together, they discuss how legal, business and technology teams can work together to balance innovation with risk and compliance. The conversation also explores the evolving debate around AI governance, online safety regulation and emerging challenges for social media companies, including Australia’s approach to protecting children online.
If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.
