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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.
Call for evidence on inheritance tax legislation
The House of Lords Finance Bill Sub-Committee has launched a call for evidence on draft legislation published in July aimed at bringing pensions into the scope of inheritance tax. The role of the Finance Bill Sub-Committee is to make recommendations on how the government's tax policy can best be implemented and administered (it does not look at the rates of tax proposed by the government). The call for evidence follows on from HMRC's technical consultation on the legislation, which closed on September 15, 2025.
The deadline for submitting evidence is 5:00pm on October 7, 2025.
PASA dashboard toolkit: use of warnings and unavailable codes
The Pensions Administration Standards Association (PASA) has published a new toolkit to support trustees, administrators and providers in applying "warning" and "unavailable" codes for pensions dashboards. Developed in consultation with the Pensions Dashboards Programme (PDP) and Money and Pensions Service, the toolkit aims to promote consistency and clarity when value data cannot be shown immediately, as this is an area where there is flexibility in the PDP data standards. The guidance outlines when various codes can be used and includes suggestions of good practice.
TPR consultation for new enforcement strategy
The Pensions Regulator (TPR) is consulting on a proposed new enforcement strategy, aiming to deliver a more risk-based, transparent and outcome-focused approach to enforcement, focusing on breaches that pose the greatest risk to savers.
Key proposals include a clearer articulation of TPR's enforcement priorities, which will be based on impact, scale and complexity; a commitment to early engagement and decisive action to prevent or limit non-compliance; and enhanced transparency around decision-making and outcomes. TPR also plans to improve communication about its expectations and enforcement activity to drive behavioural change across the industry.
Responses to the consultation should be submitted by November 11, 2025 (via TPR's online survey). After the adoption of this strategy, TPR will consider updating/consolidating its wider suite of enforcement policies and procedures. This may involve further consultation on specific policies.
Small pots feasibility review published
Pensions UK (formerly the Pensions and Lifetime Savings Association, PLSA) has published the results of a review commissioned by the DWP, of the feasibility of the government's plans for consolidating small DC pots. The review found that a centralised infrastructure model, in which records relating to individual savers' default consolidation are held and matched to scheme records e.g. a "clearing house" approach, would be costly and complex. Instead, it found that a federated, industry-delivered model, allowing pension schemes and approved consolidators to interact directly or through service providers using agreed data and message standards is the most viable option. This model works within the current framework of the draft Pensions Schemes Bill.
Whether the government adopts this recommendation remains to be seen: a number of areas of detail will need to be explored further in stage two of the Feasibility Review and secondary legislation will also be required.
Pension Academy Online, Tuesday, October 7 and Thursday, October 9, 2025
Our next Pensions Academy Online sessions will take place on Tuesday, October 7 and Thursday, October 9, 2025. Each webinar begins at 9:30am and will last approximately one hour. We will be covering:
Legal update—Tuesday, October 7, 2025
We'll round up all the latest developments and outline what's on the pensions horizon.
Pensions 2030 and beyond: preparing now for the future landscape—Thursday, October 9, 2025
The Pension Schemes Bill currently going through Parliament heralds significant change across the UK pensions landscape and more could be coming down the tracks. We'll look at how the big picture fits together, from the perspectives of trustees, employers and members, to help you plot a route from here to there.
If you would like to attend, please register here.
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.
