UK Pensions: Joint DB and DC trustee agenda—June 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 ground work 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. Most of the changes require further detail to be set out in regulations.

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 published 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 data complaints processes

Most of the provisions of the Data (Use and Access) Act 2025 (DUAA) have now been brought into force. These changes include a requirement for data controllers to have a process in place to deal with data protection-related complaints from June 19, 2026. This includes providing a complaint form that can be completed electronically; acknowledging receipt of a complaint within 30 days; responding to the complaint without undue delay; and communicating the new right to complain in privacy notices and SAR responses. The ICO has published guidance to assist data controllers.

Action: Adopt processes to address complaints in line with these requirements; review privacy notices and other communications. 

TPR warning on impersonation fraud

TPR has issued a scam alert setting out steps schemes should take following a significant increase in impersonation fraud targeting pension savers.

Action: Review the alert and implement the actions recommended by TPR.

TPR: dashboards updates

TPR has updated its dashboards guidance to answer common questions and highlight best practice, and has provided two checklists to help schemes prepare for dashboards duties. 

TPR has also updated its guidance on reporting breaches of the law to include two dashboard-related examples of “green breaches”.

It has been confirmed that 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 in workplace pension arrangements. TPR expects trustees and administrators to establish robust governance and accountability for their own, and providers’, use of AI systems and technologies; to understand how AI models use and process data, and to seek advice when required. More detailed guidance is to follow.

Action: Read the AI plan and consider the implications for your scheme. 

Watch this space

• The government is developing guidance for trustees on their fiduciary duties, aimed at supporting trustees in considering factors including systemic risks (such as climate change) and members’ standards of living.
• The government intends to consult in the coming months on issues around transfer advice, potentially including cost and availability of independent financial advice and the GBP30,000 threshold for advice on a DB transfer.
• TPR plans to publish guidance soon on the factors trustees should consider when releasing surplus.
• There is currently no date for revised regulations on changes to the notifiable events regime.

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