UK Pensions: Joint DB and DC trustee agenda—November 2025

Draft legislation for Virgin Media remedy 

The government has published draft amendments to the Pension Schemes Bill, including provisions addressing issues following the Virgin Media decision (which held that certain amendments made by schemes that were contracted-out on a section 9(2B) basis between 1997 and 2016 are void unless a necessary actuarial confirmation was provided).

The drafting sets out a process under which schemes can (subject to conditions) remedy the voiding of an alteration for lack of confirmation. This will require an actuary to confirm that it is reasonable to conclude that the alteration would not have prevented the scheme from continuing to satisfy the statutory standard at the time. The FRC has announced that it will develop guidance to help actuaries giving these confirmations.

A High Court decision is expected shortly, which may further clarify the scope of the issues.

Action: Review any Virgin Media-related projects in light of these developments.

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 any other corporate scheme structures must comply by the relevant deadlines. Voluntary verification ahead of the deadlines is encouraged by Companies House.

Have your say

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

Watch this space

• The government intends to consult on trustee accreditation and governance later this year.
• Regulations allowing multiple unconnected employers to establish a CDC scheme are expected in the autumn.
• 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.
• There is currently no date for revised regulations on changes to the notifiable events regime.

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