UK Pensions: Joint DB and DC trustee agenda—July 2026

HMRC: details on IHT changes

HMRC has published a technical note giving more details on the application of inheritance tax (IHT) to pensions and a consultation on draft regulations for the exchange of information between PRs and pension schemes is now under way. Further guidance and tools will be provided by spring 2027. Our briefing provides an overview of the changes.

Action: Start preparing for significant changes needed to comply with the new IHT requirements. 

Pension Schemes Act receives Royal Assent

The Pension Schemes Act 2026 has received Royal Assent, laying the groundwork for a range of significant changes to the UK pensions landscape. The Act includes a process to remedy invalid alterations following the decision in the Virgin Media case (see below); a framework to make it easier for DB scheme surpluses to be paid to employers; legislation for a new DC Value for Money framework and for the consolidation of small, dormant DC pots; requirements for master trust and GPP main scale default funds; the framework for guided retirement solutions; and more.

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

Virgin Media: what next?

The legislative framework to remedy historic variations to certain contracted-out schemes, where it cannot be shown that necessary actuarial certificates were provided, came into effect on April 29, 2026. The Financial Reporting Council (FRC) has finalised its non-mandatory guidance for actuaries on giving confirmations to validate historic alterations. The Pensions Regulator (TPR) has published guidance for trustees on practical points to consider in relation to the confirmation route.

Action: Consider the steps set out in TPR’s guidance. Depending on the deeds that are in issue for your scheme, you may wish to await the outcome of a forthcoming court decision that may clarify which amendments need confirmation. 

TPR: latest Annual Funding Statement

TPR’s latest Annual Funding Statement (AFS) focuses on endgame planning and current risks and provides guidance on employer covenant, supportable risk and low dependency.

Action: Review the AFS and note further clarifications about TPR’s assessment of current risks and uncertainties and clarifications of its expectations on scheme funding. 

New guide for DC wake-up packs

The Money and Pensions Service (MaPS) has published a redesigned guide to be included in “wake-up” packs for DC members.

Action: Include the new guide in wake-up packs. 

Updated VAT guidance

HMRC has made updates to its VAT input tax manual, building on a policy change announced in June 2025 in relation to VAT deduction on costs relating to DB occupational pension schemes.

Action: Review the guidance and, if appropriate, take tax advice on current arrangements. 

Company accounts reforms

The government has announced that accounts reforms will come into effect from April 2028.

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

TPR: dashboards updates

TPR has updated its dashboards guidance to answer common questions, highlight best practice, and to add two checklists to help schemes prepare. TPR has also updated its breach reporting guidance to include dashboard-related examples. The “go live” date for dashboards is likely to be in financial year 2027/28.

Action: Consider the guidance as part of dashboards compliance projects. 

TPR publishes AI plan

TPR has published an AI plan, outlining expectations for the adoption and governance of AI. TPR expects trustees and administrators to establish robust governance and accountability for use of AI systems and technologies; to understand how AI models use and process data; and to seek advice when required.

Action: Consider the implications of the plan for your scheme. More detailed guidance is to follow. 

Have your say

• The DWP has published a consultation on draft regulations setting out new conditions for the payment of DB scheme surpluses to employers. The consultation closes on September 2, 2026.
• The DWP has published a consultation on proposed amendments to the regulations setting out the red and amber flag system for pension transfers. The consultation closes on July 21, 2026.
• The DWP is running a call for evidence until July 27, 2026, asking whether the alternative quality requirements used by DB, hybrid and CDC schemes to satisfy automatic enrolment duties remain fit for purpose.
• HMRC is consulting on draft regulations intended to preserve certain annual allowance protections when pension schemes equalise Guaranteed Minimum Pensions (GMPs). The consultation closes on July 13, 2026.

Watch this space

• The government intends to consult in the coming months on issues around transfer advice.
• The government is developing guidance for trustees on their fiduciary duties.
• Pensions Minister Torsten Bell has announced that the government intends to review the legislation around Flexible Apportionment Arrangements (FAAs) “in due course”.

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