UK Pensions: DC trustee agenda update—November 2025

Corporate identity verification and filing requirements from November 18, 2025

From November 18, 2025, identity verification will be compulsory for new directors and Persons with Significant Control (PSCs) of companies; existing directors and PSCs will need to verify their identity with their next annual confirmation statement (read more). Regulations have been made applying these requirements to LLPs, which are also expected to take effect from November 18, 2025 (read more).

There will also be changes to company register requirements and the information that needs to be provided to Companies House in relation to PSCs.

Action: Corporate trustees and other corporate structures must comply by the relevant deadlines. Voluntary verification ahead of mandatory deadlines is encouraged by Companies House.

Have your say

• The Pensions Regulator (TPR) has launched a consultation on its proposed new enforcement strategy, aiming to deliver a more risk-based, transparent and outcome-focused approach to enforcement. Responses to the consultation should be submitted by November 11, 2025.

Watch this space

• Regulations allowing multiple unconnected employers to establish a CDC scheme are expected in the autumn.
• The government intends to consult on trustee accreditation and governance later this year.
• The Data (Use and Access) Act (DUA Act), which makes amendments to the UK General Data Protection Regulation and Data Protection Act 2018, has received Royal Assent. Changes include helpful tweaks to deadlines for responding to data subject access requests and new requirements around handling data protection complaints. Some regulations have been made bringing parts of the act into force but further regulations setting out details and bringing the remainder of the act into force are awaited.

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