Consultation on small pots consolidation
The government is consulting on a framework to mitigate the problem of 13 million deferred small pension pots (with over one million more added each year), carrying an estimated annual administration cost of GBP240 million. The Pension Schemes Act 2026 includes powers for the government to introduce a multiple default consolidator solution—meaning that in-scope small pots will, by default, be consolidated into one of a number of consolidator schemes (with members having the right to opt out or select an alternative consolidator). The aim is to have this system in operation from 2030.
The small pots in scope for consolidation will: (a) have been created since the introduction of auto-enrolment and held within DC charge-capped default arrangements; and (b) be valued at GBP1,000 or less and have been dormant for at least 12 months. The consultation sets out flexibilities for schemes to exclude pots from consolidation for a defined period (for example, if contributions have been intentionally paused with an intention to resume later), for pots with an associated guarantee and pots with a protected pension age (PPA) attached.
The consultation also covers the information to be provided to members; the authorisation and supervisory regime for schemes seeking to operate as a consolidator; and the digital infrastructure to enable pot matching and consolidator allocation.
The government also proposes new employer duties to provide additional information to schemes post-enrolment, including a duty to request personal email addresses from employees and provide them to schemes if supplied by employees, and to update key member details at least once every 12 months. The government is also considering whether to require employers to provide relevant information about employee status; for example, when an individual is temporarily absent from work and ceases contributing but intends to return and resume contributions.
A further consultation in late 2027/early 2028 will look at the detailed requirements for ceding schemes, the supervisory approach, data standards and other elements. The consultation ends on November 17, 2026.
Read “Small Pots: a pathway for consolidation”.
Increasing minimum AE contributions: call for evidence
The Work and Pensions Committee has launched an inquiry to inform the ongoing work of the Pensions Commission by looking at whether minimum auto-enrolment (AE) contributions should increase and, if so, how that should be split between employers and employees. The terms of reference also include the timing of any increase and whether there is a case for reducing or removing the lower earnings limit for contributions and/or the earnings trigger for AE. The deadline for responses is October 26, 2026.
Read the terms of reference and call for evidence.
Dashboards consumer testing: PDP blog post
The Pensions Dashboards Programme (PDP) has published a blog post about its consumer testing programme for the MoneyHelper Pensions Dashboard, highlighting changes already made in response to consumer feedback and how more users can get involved. The blog post includes links for schemes and employers to invite members and employees to take part in testing to familiarise themselves with dashboards, improve the user experience and, potentially, help to bring to light data or other issues for your scheme.
Read the PDP blog post.
TPR: DB funding analysis
The Pensions Regulator (TPR) has published its annual analysis of funding levels and recovery plans in occupational DB and hybrid pension schemes. The analysis is based on “tranche 19 schemes”, with effective valuation dates from September 22, 2023 to September 21, 2024 inclusive. Key findings include that 67% of schemes reported a surplus position; the average (mean) assets to technical provisions (TP) liabilities ratio for schemes was 106%, and the average (mean) recovery plan length for schemes in deficit was four years, with a median end date falling in 2027.
This is expected to be the last publication of the analysis in its current format; TPR will be reviewing its approach following the coming into force of its funding code.
Read the DB funding analysis.
Modernising corporate reporting: new consultation
The government is consulting on modernising the UK’s corporate reporting framework, proposing a wide-ranging overhaul of financial, non-financial and corporate governance reporting requirements to ensure that the UK’s framework is “the most proportionate and effective in the world”. The five principles underlying its proposals are clarity of purpose, flexibility and trust, simplicity and coherence, proportionality, and fitness for the future.
Key proposals include: clarifying that investors and creditors are the primary audience for the annual report and accounts and simplifying the rules on which entities have to report what information; reducing requirements in some areas and potentially creating a new “very large” threshold for some non-financial reporting requirements (for example, a specific new cyber risk management requirement); and reforming financial reporting requirements and reviewing strategic report requirements (including sustainability) to ensure that they are focused on matters that are financially material and provide decision-useful information for investors and creditors.
The consultation closes on November 30, 2026; the government aims to publish a response within six months.
Read “Modernising Corporate Reporting to support long-term economic growth”.
ICO replaced by Information Commission
Regulations have been made bringing into force various provisions of the Data (Use and Access) Act 2025 to replace the Information Commissioner with the Information Commission from September 30, 2026. All references to the Information Commissioner in UK law should automatically be taken to mean the Information Commission from that date. Scheme communications should be updated in due course. Helpfully, we understand that the Information Commission’s Office will continue to be known as the ICO.
Read the ICO governance changes press release and the regulations.
Pensions Academy Online: Tuesday, September 29 and Thursday, October 1, 2026
Our next Pensions Academy Online sessions will take place on Tuesday, September 29 and Thursday, October 1, 2026. Each webinar begins at 9:30am and will last approximately one hour. We will be covering:
Legal update—Tuesday, September 29, 2026
Our regular round-up of all the latest developments in the legal corner of the occupational pensions world.
AI: the good, the bad and the future—Thursday, October 1, 2026
We are thrilled to welcome Cliodhna Judge, TPR’s external market oversight lead for emerging governance topics, including cyber and AI, for a session exploring what artificial intelligence means for UK pension schemes. Cliodhna will join Francesca Parnell, counsel at A&O Shearman, to explore the opportunities, risks and regulatory direction of travel. Expect insights on where AI can help your scheme and members, the risks to watch out for, and what TPR expects from schemes today and into the future.
Click here to register for either or both sessions.
