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Welcome to our monthly update on current legal issues for trustees of DC pension schemes, designed to help you stay up to date with key developments between trustee meetings and to support the legal update item on your next trustee agenda. We have a separate update for DB/hybrid schemes.
Pension Schemes Act—details of proposals and timing
A revised roadmap setting out timelines for the implementation of the changes in the Pension Schemes Act 2026 has been published, alongside various related documents:
- A consultation on the Value for Money framework (see below). TPR has published overviews of the framework and proposed digital solution
TPR has published a new web page summarising the changes introduced by the Act and how to prepare.
Action: Most areas require a watching brief for now, pending regulations.
New guide for DC wake-up packs
The Money and Pensions Service (MaPS) has published a redesigned guide to be included in “wake-up” packs for DC members.
Action: Include the new guide in wake-up packs.
TPR: dashboards updates
The Pensions Dashboards Programme (PDP) has confirmed a revised timetable for new daily dashboards reporting requirements. Organisations that have not yet implemented daily reporting will be required to submit some key metrics manually (via file upload) until implementation is complete. The PDP has published guidance on how to report manually commencing in October (for September 2026 data).
Action: Ensure you are prepared for the reporting requirements.
Company accounts and corporate reforms
The government has updated its guidance and timetable in relation to the implementation of various corporate and accounts reforms. These include: requiring filing of profit and loss accounts; requiring use of commercial software; removing the option of abridged accounts; a strengthened eligibility statement for companies claiming an audit exemption; and changed filing requirements.
Action: Corporate trustees should review whether they are impacted by the changes.
Have your say
- A consultation on draft Value for Money regulations has been launched, including phased implementation and more lead-in time. The consultation deadline has been extended to September 15, 2026.
- A consultation on changes to the General Levy has been launched, closing at midday on September 8, 2026.
- HMRC is consulting on transitional rules for individuals who have reached age 55 when the normal minimum pension age increases from 55 to 57 in April 2028. The deadline for responses is September 28, 2026.
Watch this space
- The government is developing guidance for trustees on their fiduciary duties.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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