Roundup

UK Pensions: DC trustee agenda update—November 2026

UK Pensions: DC trustee agenda update—November 2026
Welcome to our monthly update on current legal issues for trustees of DC pension schemes, designed to help you stay up to date with key developments between trustee meetings and to support the legal update item on your next trustee agenda. We have a separate update for DB/hybrid schemes.

TPR guidance on AI concentration risk

The Pensions Regulator (TPR) has published guidance setting out steps it expects trustees to take to manage concentration risk arising from the rapidly increasing influence of AI on global markets.

Action: Review the guidance and consider TPR’s recommended actions.

New bereavement leave from April 2027

The government has published a consultation response setting out its proposals for new entitlements to bereavement leave, which are intended to take effect from April 2027. Bereavement leave will be available in the case of a pregnancy loss before 24 weeks and the loss of a loved one.

Action: Further regulations are needed to provide the full details, but schemes should be prepared to review and, if necessary, update their rules before the changes come into force in April.

Dashboards updates

The Pensions Dashboards Programme (PDP) has confirmed a revised timetable for new daily dashboards reporting requirements. Organisations that have not yet implemented daily reporting will be required to submit some key metrics manually (via file upload) until implementation is complete. The PDP has published guidance on how to report manually and a draft updated version of the dashboards reporting standards to support implementation of the change. The PDP has also published new guidance for directly connecting organisations (DCOs).

Action: Ensure you are prepared for the reporting requirements; DCOs should review the new guidance.

Inheritance tax and pensions—further HMRC guidance

HMRC has published a second technical note on the upcoming changes bringing most pension benefits into the scope of inheritance tax (IHT) from April 2027. The note focuses on information sharing between personal representatives and pension scheme administrators. It also includes an outline of upcoming HMRC guidance and materials.

Action: Ensure your administrative processes and governance are ready for the IHT changes.

Have your say

Watch this space

  • The government is developing guidance for trustees on their fiduciary duties.
  • HMRC has indicated that the government will legislate to simplify the taxation of certain lump sum death benefits paid in excess of the lump sum and death benefit allowance.
  • The Treasury has confirmed that the government will review the rules on allowing access to pension savings in cases of terminal illness.

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