UK Pensions: Joint DB & DC trustee agenda—May 2026

Finance Act receives Royal Assent

The Finance Act 2026 has received Royal Assent. The Act will bring most pension benefits into the scope of inheritance tax (IHT) from April 6, 2027. This will require schemes to have new processes for calculating relevant benefits; communicating with personal representatives (PRs); withholding payment of benefits; and paying tax directly. The government has confirmed that it will consult on regulations on exchange of information between PRs and pension schemes this spring, and further guidance and tools will be provided by spring 2027.

Action: Schemes should start preparing for significant changes needed to comply with the new IHT requirements.

Virgin Media confirmations guidance

The Financial Reporting Council (FRC) has published non-mandatory guidance for actuaries on giving confirmations under the Pension Schemes Bill (PSB) to validate historic alterations. This follows the Virgin Media decision, which held that historic variations to certain contracted-out schemes were void where it could not be shown that necessary actuarial certificates had been provided.

The Pensions Regulator (TPR) has published guidance for trustees on practical points to take into account when considering using the confirmation route.

Action: Unless there is a need to address Virgin Media issues quickly, consider the initial steps set out in TPR’s guidance and keep a watching brief: the provisions of the PSB are still to be finalised and a court decision is awaited which may impact which amendments need confirmation.

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 updates on dashboards compliance

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

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

Updated master trust reserving guidance

TPR has updated its guidance around regulatory capital reserving requirements for master trusts.

Action: Master trust clients should consider the new guidance.

PPF final levy rules

The Pension Protection Fund (PPF) has published its levy policy statement and final rules for 2026/27, confirming no levy for conventional schemes. Schemes are still required to submit an annual scheme return submission in full via Exchange, including s179 valuations and asset-backed contribution information, but will not need to provide other information previously submitted to the PPF.

Action: Ensure scheme returns and relevant information are submitted.

DC scale requirements and consolidation guidance

The DWP and TPR have produced guidance on the upcoming requirements for DC multi-employer AE schemes to have a main scale default arrangement holding at least GBP25 billion in assets by 2030. TPR has also published a blog post encouraging smaller DC schemes to consider whether continuing to run on is realistic, alongside consolidation guidance and updated winding-up guidance.

Action: Affected schemes should consider the guidance in their preparations for compliance.

Family leave changes

A number of changes are being made to family leave, including introducing a new entitlement to bereaved partner’s paternity leave.

Action: Review rules to confirm whether changes are needed; make sure family leave policies and procedures reflect these updates.

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.

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 in early May 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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