Roundup

UK Pensions: What’s new this week? February 9, 2026

UK Pensions: What’s new this week? February 9, 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

New UK data protection rules take effect—pension schemes must implement formal complaints handling procedures and will see revised SAR requirements and other data-related changes.

PASA dashboards Q&A —PASA addresses practical dashboards questions on identity verification, fraud risk, data matching, testing, launch capacity, and user communications.

PPF levy ceiling updated—the 2026/27 PPF ceiling Order has been published but the PPF’s intention to maintain a zero levy for conventional schemes means it is likely to be academic.

Plus: Pensions Academy Online—dates, topics and a link to register for our upcoming webinars.

Data (use and access) act—requirements for complaints process and other changes  

From June 19, 2026, under the Data (Use and Access) Act (DUAA), data controllers will need to have a process in place to deal with data protection-related complaints. This includes: providing a complaint form which can be completed electronically and by other means; acknowledging receipt of the complaint within 30 days; and responding to the complaint without undue delay. Schemes should ensure appropriate processes are being put in place to identify and process complaints in line with these requirements.  

Other provisions of the DUAA came into force on February 5, 2026, including:

  • Responses to subject access requests (SARs): timing changes, including being able to “stop the clock” to gather additional information, and to extend the deadline for complex or numerous requests; plus information requirements if a SAR is refused because it is unfounded or excessive.
  • Detail on when data can be processed for a purpose other than that for which it was originally collected.
  • Narrowing the prohibition on automated decision-making.
  • Changes to requirements on making data transfers to third countries or international organisations.

Read the commencement regulations and the ICO’s statement on the commencement

PASA dashboards Q&A

The Pensions Administration Standards Association has published a Q&A document addressing practical issues with dashboards. The areas covered include: identity verification and fraud risk; data verification and matching; the testing process; dealing with high volumes of users at launch; and information/warnings to be provided to users.

Read the dashboards Q&A document. 

PPF levy ceiling updated 

The annual Order increasing the Pension Protection Fund (PPF) levy ceiling amount has been published. The levy ceiling is increased annually in line with growth in the general level of earnings; the Order restricts the amount that can be collected by the Board of the PPF for the 2026/27 financial year. Given the PPF’s announcement that it intends to maintain a zero levy for conventional schemes, the levy ceiling may never come into play.

Read the PPF levy ceiling Order.

Pensions academy online: Tuesday, March 3 and Thursday, March 5, 2026

Our next Pensions Academy Online sessions will take place on Tuesday, March 3 and Thursday, March 5, 2026. Each webinar begins at 9:30am and will last approximately one hour. We will be covering: 

Unlocking the next generation of DB endgame strategies—Tuesday, March 3, 2026 

The DB endgame conversation is accelerating, with government and TPR pushing schemes to rethink their long term destination. But what does this shift really mean in practice? Join us for a practical, insightful session exploring the full spectrum of endgame options—from buy-out and winding up to emerging, innovative approaches. We’ll share real world lessons, including from our experience of advising on the recent ground-breaking Stagecoach derisking transaction, to help you navigate what’s possible and what’s coming next for your scheme. 

Legal update—Thursday, March 5, 2026

The pensions agenda for 2026 is jam-packed with change. Join us for a clear, practical walkthrough of the latest developments and what’s coming down the track—so you can quickly get to grips with what your scheme needs to focus on to stay compliant, well governed, and ahead of the curve.

If you would like to attend, please register here

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