UK Pensions: DC trustee agenda update – July 2025

Pension Schemes Bill 2025 published

The Pension Schemes Bill has been published, containing a raft of changes to the DC pensions landscape, including: a value for money framework; requirements for master trusts and GPPs to have a default fund with a minimum level of assets under management and potentially a prescribed level of investment in "productive assets"; a framework for consolidation of small, dormant pots; and requirements for schemes to provide members with a guided retirement product. Regulations will set out the details of the proposals. Read more.

A roadmap published alongside the bill sets out a guideline of timings for the various changes. The aim is that the bill will be passed at the start of 2026.

Action: Keep a watching brief as the bill progresses and regulations are published. Arrange training on the aspects that affect your scheme.

TPR guidance on market volatility

The Pensions Regulator (TPR) has published a market oversight report setting out guidance and best practice for trustees on preparing for and responding to market volatility in light of recent trade and geopolitical tensions. 

Action: Review the guidance and consider which actions are relevant to your scheme.

Dashboards: DPIA and guidance on split administration published

The Pensions Dashboards Programme (PDP) has published its data protection impact assessment (DPIA) for processing in relation to the central dashboards architecture. Schemes are responsible for completing a DPIA for their own dashboards processing.

The PDP has also published a blog post setting out guidance on dashboards connection via a third party and a progress update report. Guidance from PASA includes reassurance from TPR for schemes with split administration that cannot connect all benefits on the same date.

Action: Ensure your scheme/administrator/ISP is on track for complying with your dashboards connection deadline. Complete a DPIA for your scheme’s dashboards processing.

Upcoming rules on identity verification and corporate filing

Changes under the Economic Crime and Corporate Transparency Act (ECCTA), intended to prevent the use of corporate entities for criminal purposes, are being brought in gradually. By autumn 2025, identity verification is expected to be compulsory for new directors and Persons with Significant Control (PSCs); there will be a 12-month transition phase for existing directors and PSCs. Companies House has launched a service allowing individuals to verify their identity voluntarily. From spring 2026, new restrictions on who can file documents at Companies House on behalf of companies are expected.

Action: Corporate trustees should keep a watching brief and begin identifying procedures which will need updating. Consider whether you wish to voluntarily verify identities ahead of mandatory requirements. Read more here.

TPR supervision of professional trustees

TPR has announced that it will be extending its oversight of professional trustee (PT) firms. It will begin targeted engagement with larger PT firms in the summer, extending its approach to cover remaining firms by the end of the year. It will use this process to identify risks and appropriate mitigations and expectations.

Action: Professional trustees should prepare to be contacted by TPR and questioned on the key focus areas.

Watch this space

• The second stage of the government’s Pensions Investment Review will be launched "shortly".
• 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.

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