TPR: new guide to Pension Schemes Act and targeting DC compliance
The Pensions Regulator (TPR) has published a new web page for pension scheme trustees, managers and advisers, summarising the changes introduced by the Pension Schemes Act 2026, with guidance on how to prepare. The page will be updated regularly as secondary legislation develops and detailed guidance is published.
Alongside the web page, TPR has launched a campaign targeting compliance by DC schemes. TPR has begun a direct communications programme to “set clear expectations, show what good looks like and provide practical guidance”. Phased communications will include regular emails encouraging trustees to reflect on their ability to comply and to start preparing. TPR reiterates previous messaging about the drive towards fewer, larger schemes, encouraging trustees to “assess if they can meet the higher legislative standards—or if members would benefit from consolidation into a scheme that can provide scale, value and good governance”.
TPR gives some updates on the timing of next steps:
- Guidance supporting the DWP consultation on value for money assessments is planned this summer.
- It plans to consult on detailed guidance on the new DB surplus release powers in “late autumn 2026”.
- “Roadmap” publications coming soon will set out more detail on Pension Schemes Act implementation.
Visit the Pension Schemes Act 2026 web page and read the blog post on DC compliance.
TPR blog post on DB innovation
TPR has published a blog post on innovation in the DB landscape, as increased funding levels lead trustees to consider alternative endgame options. The post highlights TPR’s constructive role in the December 2025 Stagecoach transaction, in which sponsorship of the Stagecoach Group Pension Scheme transferred to Aberdeen. The post notes that the trustee proactively approached TPR to discuss options and worked with TPR to find a solution which would allow them to run-on, pay an immediate uplift to benefits, and share potential ongoing surplus between the members and the new sponsor.
TPR notes the government’s announcement of a review of flexible apportionment arrangements following the transaction, which it sees as “an important opportunity for industry stakeholders to contribute their expertise and help shape a proportionate and effective approach”. Pending any reform, TPR says it will consider an interim approach to transactions with similar characteristics. TPR notes that supporting innovation in savers’ interests remains a key pillar of its strategy, and it encourages early engagement by anyone considering new models or novel proposals via its innovation support service.
Read the blog post.
PDP confirms revised timetable for daily dashboards reporting
The Pensions Dashboards Programme (PDP) has published a response to its consultation on updated reporting standards, which proposed changes largely aimed at requiring daily, automated reporting of data. The PDP has extended the mandatory implementation deadline to March 1, 2027 (from a proposed deadline of November 30, 2026), although the intention remains that parties should be able to report daily before the end of November 2026. Voluntary, sequenced testing and implementation should begin from summer 2026. From autumn 2026, organisations that have not yet implemented daily reporting will be required to submit some key metrics manually until implementation is complete.
Read the consultation response.
TPO publishes new information leaflets
The Pensions Ombudsman (TPO) has published four new information leaflets aimed at pension scheme members. The leaflets cover:
- Death benefit lump sums—explaining what death benefits are; common complaints; and how TPO can help if a dispute cannot be resolved.
- How to complain about your pension—covering how to raise a concern informally; how to make a formal complaint (including how the IDRP process works); when TPO may be able to help; and the time limits for applying.
- Ill health pensions—explaining what an ill health pension is, common complaints and how TPO can help.
- Incorrect information about your pension—explaining what incorrect information is; what to expect when it is received; common complaints; and how TPO can help.
Schemes may wish to signpost these leaflets to members who raise queries or complaints on these topics.
Legislation addressing disparity in net pay arrangements
In 2023, the government introduced legislation intended to address the disparity arising from differences in tax relief between low earners contributing to pensions via net pay arrangements and those contributing via relief at source schemes. That legislation introduced a top-up arrangement (the Low Earner’s Pension Payment) but it has become apparent that not all individuals intended to be covered are eligible for the top-up under the current provision. New regulations coming into force on July 14, 2026 will amend the earlier legislation to resolve this issue.
Read the Registered Pension Schemes (Net Pay Arrangements) Regulations 2026.
PPF levy legislation enacted
Regulations have been made bringing provisions in the Pension Schemes Act 2026 relating to the PPF levy into force. Those provisions are largely aimed at enabling the PPF to raise a zero levy. The PPF has confirmed it will not charge a conventional levy for 2026/27.
Read the Pension Schemes Act 2026 (Commencement No. 1) Regulations 2026.
HMRC: latest pension schemes newsletter
HMRC has published its latest Pension Schemes Newsletter (no. 182). The newsletter refers to HMRC’s consultation on preserving annual allowance protections on GMP conversion. It also covers: changes to ID verification for scheme administrators and practitioners; a delay to the digitalisation of the relief at source strategic payments service; use of deconsolidated references for relief at source claims and adjustments; and updated guidance for employers reporting employee pension contributions.
Read the newsletter.
High Court grants rectification to remove “Courage” restriction
The High Court has granted rectification of scheme rules to allow removal of a Courage-style restriction: Soufflet Bairds Malt Ltd & Anor v. Dear [2026] EWHC 1480 (Ch). The scheme had been administered on the basis that it had been closed to accrual since March 31, 2010. However, deeds entered into in 2004 and 2012 introduced a proviso to the amendment power protecting benefits “already accrued or secured”. This operated as a Courage-type fetter that arguably meant the closure to accrual did not break members’ final salary link.
The judge approved rectification to remove the proviso wording. The judge took into account a range of “particularly compelling” evidence, including:
- explanatory guides prepared by the scheme’s professional advisers did not identify the introduction of any new fetter
- the broader context—the scheme was expensive to fund and the employer's financial position was poor—meant that introducing a fetter would have been surprising and would have prompted discussion at trustee or board level (and trustee minutes included no reference to this)
- the draft deed was based on the legal adviser’s precedent, not specific to the scheme
- events after execution—the final salary link was treated by both the employer and the trustee as a matter for negotiation, not as an entrenched entitlement.
Read the case.
