Roundup

UK Pensions: What’s new this week? August 17, 2026

UK Pensions: What’s new this week? August 17, 2026

Welcome to your weekly update from the A&O Shearman Pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions.

Summary

Value for Money framework: extended consultation deadline plus new overviews from TPR and guidance for trustees on getting ready for the forthcoming requirements.

Pensions dashboards: new PASA guidance on responding to member queries about dashboards.

ECCTA: updated timetable for implementation of various reforms.

Upper Tribunal rules that reliance on advisers did not excuse non-compliance with HMRC notices.

VfM: TPR overviews and extended consultation

The Pensions Regulator (TPR) has published an overview of the proposed Value for Money (VfM) framework, intended to help trustees and scheme managers of affected DC schemes understand the upcoming regime. The deadline to respond to the VfM consultation has been extended to September 15, 2026.

As well as summarising the proposals, the overview highlights changes in the latest consultation, including a phased approach, more lead-in time for some data collection and changes to areas such as comparators, publication and investment metrics. TPR encourages schemes to begin preparing now, starting by understanding which default and quasi-default arrangements are likely to be in scope and identifying the data required and how and when this will be made available.

The overview is accompanied by a flowchart intended to help schemes decide whether the requirements apply, which arrangements must be assessed and when.

TPR has also published a technical overview of the proposed digital solution for data submission, comparisons and reporting, providing insight into how this TPR-operated service is expected to work.

Read the VfM overview, VfM scope flowchart, and VfM digital service: technical overview.

PASA guidance on responding to member dashboard queries

The Pensions Administration Standards Association (PASA) has published interim guidance to help with responding to member queries on pensions dashboards. The guidance includes suggested responses to frequently asked questions such as “What are dashboards?”, “What will they show?” and “How can they be accessed?”

Read the interim PASA guidance

ECCTA: updated timetable

Companies House has updated its intended timetable for implementation of various reforms under the Economic Crime and Corporate Transparency Act (ECCTA). Some of these changes will affect corporate trustees: for example, compulsory identity verification for any presenter filing a document at Companies House has been delayed until November 2027 and a number of requirements have been postponed until April 2028, including the requirement for small companies and micro entities to file profit and loss accounts, various changes to the filing of accounts and other reporting requirements. 

Read the updated ECCTA timetable

Adviser reliance not a reasonable excuse for non-compliance with HMRC notices

The Upper Tribunal has upheld a decision that two pension scheme administrators had no reasonable excuse for failing to comply with HMRC information notices, despite relying on advice obtained through the schemes’ practitioner and a tax adviser: Hill and McCracken v. HMRC.

The notices—and escalating penalties for non-compliance—were issued to the individuals personally, but their advisers told them that no response was needed and fines did not need to be paid because the relevant pension schemes had been wound up and the advisers were pursuing an appeal.

The tribunal accepted that taxpayers are not required to second-guess professional advisers or obtain multiple opinions, but they must still take reasonable care to avoid failing to comply with an information notice. Here, that meant asking obvious questions about the basis for the advice, checking whether factual assumptions were correct, and understanding what correspondence was being sent to HMRC on their behalf.

The appeal on reasonable excuse therefore failed, although the Upper Tribunal found an error in the approach to the quantum of penalties.

Read the Hill and McCracken v. HMRC decision.

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