UK Pensions: DC trustee agenda update – January 2026

Autumn budget—pensions announcements NEW

The Chancellor announced in her autumn Budget the introduction from April 6, 2029 of an annual cap of GBP2,000 on the amount of pension contributions that are exempt from National Insurance Contributions (NICs) through salary sacrifice. Draft legislation has been published on this.

The Budget also announced changes to earlier proposals to bring pensions into the scope of inheritance tax (updates to the previous draft legislation have been published). Other changes included providing inflationary increases on pre-97 PPF compensation and allowing CDC schemes (see below) to be registered. 

ACTION: Employers operating salary sacrifice may want to review these arrangements. Keep a watching brief on inheritance tax changes.

TPR: revised administration guidance NEW

The Pensions Regulator (TPR) has published new guidance outlining steps that trustees, scheme managers and administrators should take to comply with the administration module of its Code of Practice. This replaces previous guidance and sets out more detailed requirements for schemes, including formal policies and prioritising data, stronger IT/automation/cyber focus, and tighter administrator engagement and oversight. 

ACTION: Review the new guidance to identify further steps that could be taken to improve governance of scheme administration—schemes undertaking their own-risk assessment may wish to build some of these steps into their future plans. 

TPR: revised data guidance

TPR has published revised guidance on member data. The guidance consolidates all previous data related guidance into one place and is intended to set out clearer expectations (including best practice examples) to help schemes achieve better data management.

ACTION: Review the guidance and consider whether your scheme is complying with TPR’s expectations.

CDC regulations and consultation

The government has published a consultation response, draft regulations and a new consultation on Collective Defined Contribution (CDC) arrangements (where investments are held in, and benefits paid from, a collective fund, providing an unguaranteed target annual income). The draft regulations allow unconnected employers to participate in a CDC arrangement.

The new consultation looks at options to allow DC savers to transfer into a CDC scheme at retirement. This could provide a decumulation income option (in line with the forthcoming guided retirement framework). 

ACTION: Consider whether CDC could be of interest to your scheme, in particular in light of upcoming guided retirement requirements. 

Have your say

• The government has launched a consultation on trusteeship and governance, looking at various issues including trustee appointment and tenure; accreditation; professional trustees and how to improve administration. The deadline for responses is March 6, 2026.
• The Information Commissioner’s Office (ICO) is consulting on draft updated statutory guidance on investigations and enforcement under the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018. The consultation closes on January 23, 2026. 

Watch this space

• The pensions minister has announced that he intends to consult on legislation that will allow the government to develop statutory guidance for trustees on their fiduciary duties, intended to support trustees in considering factors including systemic risks (such as climate change) and members’ standards of living.
• 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 Dua Act into force, but further regulations setting out details and bringing the remainder of the Dua Act into force are awaited.