UK Pensions: What’s new this week? December 22, 2025

Consultation on trusteeship and governance

The government has published a consultation on trusteeship, governance and administration. The deadline for responses is March 6, 2026.

What aspects of trusteeship and governance is the government consulting on?

• The big picture: Broad questions on what is working well currently, what the barriers to good trusteeship are and what support is needed in the future.
• Trustee appointment: Whether any further controls or safeguards on appointments are needed; whether there should be any limits on appointment length and/or on repeat appointments to the same trust; and how government and regulators can encourage diversity and talent.
• Trustee directory: How to obtain the necessary information for a complete directory of trustees. This would include whether a trustee is a professional trustee (which would require a statutory definition of "professional trustee") or member-nominated, any accreditation and levels of toolkit completion. The register would be used by TPR for interaction with schemes and there is no intention for the registry to be published publicly.
• Professional trustees: The growing role of professional trustees is a key focus and the consultation seeks input on whether there should be higher statutory requirements for professional trustees and what those should be; whether safeguards are needed to manage conflicts of interest where additional services are provided; whether there should be a restriction on the number of appointments; and, for sole trustees, whether there should be any restrictions or guidelines on appointments and an enhanced code of practice.
• Lay trustees (and absence of): What support/continuing professional development (CPD) should be put in place for lay trustees; should they be accredited, and what important benefits or skills should be replicated in consolidated structures which may not have lay trustees? Linked with this, how can the government ensure trustee boards take into account members’ perspectives in decision-making?
• Administration: Whether scheme administrators should be subject to mandatory minimum standards and whether they should be regulated by TPR. The consultation also asks for feedback on the risk of a disorderly exit from the market by one of the big third-party administrators.

The consultation also seeks input on whether there are conflict of interest issues in master trusts and whether the upcoming "megafund" requirements (that AE master trusts must have a minimum of GBP25 billion in assets under management by 2030) require any governance or regulatory changes. Finally, the government is exploring whether a public trustee should be introduced for situations in which TPR can appoint or replace trustees.

Read the consultation.

TPO factsheet on overpayments

The Pensions Ombudsman (TPO) has published a factsheet for members on what happens when a pension has been overpaid. TPO is asking schemes to share this information with members, ideally when informing them of an overpayment or when a member queries or challenges the scheme’s attempt to reclaim an overpayment. Schemes should check with administrators whether processes are being updated to provide this information.

Read the factsheet.

Auto-enrolment trigger and earnings band to remain unchanged

The government has confirmed that automatic enrolment thresholds will remain unchanged for 2026/27:

• The auto-enrolment earnings trigger will remain at GBP10,000.
• The lower and upper limits of the qualifying earnings band will remain at GBP6,240 and GBP50,270, respectively.

Read the announcement.

TPR master trust bulletin (also helpful for other schemes)

TPR has published the December edition of its master trust bulletin, covering a range of issues (some of which are helpful for non-master trust schemes), including:

• AI: TPR suggests that trustees could consider including additional risk warnings in scheme documentation and member communications on the use of AI to inform decisions about their pension arrangements.
• DC fund illustrations: The bulletin reports on the DWP’s view on methods being used for DC fund illustrations and that it intends to consult on this.
• Fund disclosures: The bulletin includes guidance communicating fund options to members.
• Significant events guidance: TPR will publish further guidance on significant events next year.
• Investment risk frameworks: TPR encourages schemes to review and update their governance and risk management frameworks.
• Structured equity solutions and defence investment: The bulletin outlines key areas to consider if exploring new investments involving restructuring physical passive equity portfolios into more complex arrangements. It also discusses how trustees should consider defence investment opportunities.

Read the bulletin.

HMRC Pension schemes newsletter

HMRC’s latest Pension Schemes Newsletter (no. 176) covers: reporting a transfer to a qualifying recognised overseas pension scheme (QROPS) on the Managing Pension Schemes service; new requirements for tax advisers who interact with HMRC on behalf of clients to register and meet minimum standards; an update that the new service for looking up members’ protections and enhancements will go live in early 2026; information on residency status reports for relief at source schemes; and a reminder on deadlines for submitting pension scheme returns and event reports: January 31 after the end of the tax year.

Read the newsletter.

Pensions dashboards programme (PDP) guidance: Downtime and data management

The PDP has published guidance on how schemes should manage planned and unplanned downtime, and on data management for organisations connecting directly to the dashboards ecosystem.

Read the downtime guidance and the data management guidance.

TPR annual report on the DB landscape

The Pensions Regulator’s annual overview of the occupational DB and hybrid scheme landscape shows continuing trends of year-on-year reduction in the number of schemes and in the number of scheme memberships. On funding levels, the percentage of schemes in technical provisions surplus is 82%, compared to 80% in 2024.

Read the report.

Holiday arrangements

This is our final edition of "What’s New This Week" for 2025; our next edition will be published on January 12, 2026.

We hope you have a happy and restful break.