DC trustee agenda update: current legal issues—September 2026

Pension Schemes Act—details of proposals and timing  

A revised roadmap setting out timelines for the implementation of the changes in the Pension Schemes Act 2026 has been published, alongside various related documents: 

• A consultation on the Value for Money framework (see below). TPR has published overviews of the framework and proposed digital solution

• A DC scale requirements discussion paper

• Principles for guided retirement

TPR has published a new web page summarising the changes introduced by the Act and how to prepare. 

Action: Most areas require a watching brief for now, pending regulations. 

Company accounts and corporate reforms

The government has updated its ECCTA guidance and ECCTA timetable in relation to the implementation of various corporate and accounts reforms. These include: requiring filing of profit and loss accounts; requiring use of commercial software; removing the option of abridged accounts; a strengthened eligibility statement for companies claiming an audit exemption; and changed filing requirements. 

Action: Corporate trustees should review whether they are impacted by the changes.

Have your say

• A consultation on draft Value for Money regulations has been launched, including phased implementation and more lead-in time. The consultation deadline has been extended to September 15, 2026. 
• A consultation on changes to the General Levy has been launched, closing at midday on September 8, 2026. 
• HMRC is consulting on transitional rules for individuals who have reached age 55 when the normal minimum pension age increases from 55 to 57 in April 2028. The deadline for responses is September 28, 2026.

Watch this space 

• The government is developing guidance for trustees on their fiduciary duties.

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