Roundup

UK Pensions: What's new this week—November 3, 2025

UK Pensions: What's new this week—November 3, 2025
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.
 

HMRC pension schemes newsletter 

HMRC’s latest Pension Schemes Newsletter (no. 174) includes reminders on various topics, including the requirement that from April 6, 2026 all pension scheme administrators of a UK registered scheme must be UK resident.

Following on from a previous article on the tax consequences of cancelling a pension commencement lump sum or uncrystallised funds pension lump sum, the newsletter also provides more information on issues including restrictions on recycling a lump sum and HMRC’s expectations around reporting. HMRC may challenge alternative interpretations of the tax consequences where a tax-free lump sum is returned after December 5, 2024.

Read the newsletter.

TPR’S regulatory round-up

The Pensions Regulator’s (TPR’s) latest Regulatory Round-Up newsletter includes:

  • Dashboards: a link to new video resources and an invitation to register for a webinar on December 3, 2025 covering lessons learned from schemes that have already connected, and key elements of operational readiness.
  • A reminder about the importance of good investment governance in the face of current concerns about private credit and price appreciation in the tech sector, and wider political instability.
  • Information about changes to the 2026 scheme return for DB and hybrid schemes, which will introduce a requirement to provide a more detailed breakdown of the unquoted/private equity asset class (including sub-categories such as venture capital, private equity and infrastructure equity, along with a UK/non-UK split). TPR will also require further information on arrangements supporting leveraged liability-driven investments.

Read TPR’s Regulatory Round-Up.

FRC guidance for UK stewardship code reporting

The updated UK Stewardship Code 2026 takes effect from January 1, 2026. Among other changes, the revised code includes dedicated principles for different types of signatories, including asset owners, asset managers, investment consultants and engagement service providers.

The Financial Reporting Council (FRC) has now published guidance to assist with reporting against the new code, including guidance on policy and context disclosures and on the activities and outcomes report. The guidance is optional and is intended to support organisations exercising stewardship in different ways.

Read the guidance.

PASA guidance on the use of AI in pensions administration

The Pensions Administration Standards Association (PASA) has published guidance on the use of AI in pensions administration. The guidance looks at the opportunities and the risks of adopting AI within pensions administration, including the need for good quality data, the increased risk of data breaches and unauthorised access and how this might be mitigated, and potential risks around data bias and decision-making processes. The guidance highlights the need for human review and oversight in AI-driven processes and for AI applications to cater for scheme-specific requirements.

Read the PASA guidance.

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