UK Pensions: Joint DB & DC trustee agenda update - July 2025

Government to provide Virgin Media fix  

The government has announced that it will help with uncertainty 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 government will ‘give affected pension schemes the ability to retrospectively obtain written actuarial confirmation that historic benefit changes met the necessary standards’. No further details are currently available. A High Court decision is expected shortly which may further clarify the scope of the issues.

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

TPR endgame guidance

The Pensions Regulator (TPR) has published new guidance for DB schemes when deciding their endgame strategy. The guidance discusses running-on schemes and sharing surplus with employers, as well as a number of other endgame options.

Action: Take the guidance into account when considering endgame strategy.

Pension Schemes Bill 2025 published

The Pension Schemes Bill has been published, containing a raft of changes to the pensions landscape, including: easier release of DB surpluses to employers; a DC value for money framework; requirements for master trusts and GPPs to have a default fund with a minimum level of assets under management and potentially a prescribed level of investment in ‘productive assets’; a framework for consolidation of small, dormant DC pots; requirements for schemes to provide DC members with a guided retirement product; and a legislative framework for DB superfunds. Read more.

Action: Keep a watching brief as the bill progresses and regulations are published. Arrange training on the aspects that affect your scheme.

TPR guidance on market volatility

TPR has published a market oversight report setting out guidance for trustees on preparing for and responding to market volatility in light of recent trade and geopolitical tensions. It sets out best practice actions for trustees of DB and DC schemes.

Action: Review the guidance and consider which actions are relevant to your scheme.

TPR annual funding statement

TPR has published its latest annual funding statement. Although targeted at schemes with valuation dates between September 22, 2024 and September 21, 2025, it includes important information for all occupational DB schemes. It sets out guidance on: the application of the new DB funding regime (focused on assessing and monitoring employer covenant and supportable risk); approaching scheme surpluses; and considerations in relation to macroeconomic uncertainty. 

Action: Review the guidance and take any relevant recommended actions.

TPR supervision of professional trustees

TPR has announced that it will be extending its oversight of professional trustee (PT) firms. It will begin targeted engagement with larger PT firms in the summer, extending its approach to cover remaining firms by the end of the year.

Action: Professional trustees should prepare to be contacted.

Dashboards: DPIA and guidance on split administration published

The Pensions Dashboards Programme (PDP) has published its data protection impact assessment (DPIA) for processing in relation to the central dashboards architecture. Schemes are responsible for completing a DPIA for their own dashboards processing.

The PDP has also published a blog post setting out guidance on dashboards connection via a third party and a progress update report. Guidance from PASA includes reassurance from TPR for schemes with split administration (e.g. a separate AVC provider) that cannot connect all benefits on the same date.

Action: Ensure your scheme/administrator/ISP is on track for complying with your dashboards connection deadline. Complete a DPIA for your scheme’s dashboards processing.

Upcoming rules on identity verification and corporate filing

Companies House has launched a service allowing individuals to verify their identity voluntarily. This comes in advance of requirements for verification of new directors and Persons with Significant Control (PSCs) expected in autumn, under the Economic Crime and Corporate Transparency Act.

Action: Corporate trustees should begin identifying procedures which will need updating. Consider whether to voluntarily verify identities.

Watch this space

• The second stage of the government’s Pensions Investment Review will be launched ‘shortly’.
• 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.
• There is currently no date for revised regulations on changes to the notifiable events regime.

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