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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.
Box Clever saga ends in settlement
The Pensions Regulator (TPR) has announced that its lengthy dispute with ITV about the Box Clever pension scheme has ended with an agreement to settle the case, under which all members of the Box Clever scheme will receive their pension benefits in full. TPR has published a regulatory intervention report setting out the details of its investigation and enforcement process and the dispute and settlement.
TPR's anti-avoidance investigation began in 2011 following the collapse of Box Clever, which was a joint venture between Granada (now ITV) and Thorn (now Carmelite). ITV had extracted significant value from the joint venture and was issued with financial support directions (FSDs). ITV sought to challenge the decision to issue FSDs through lengthy litigation pursued before the Upper Tribunal, Court of Appeal and Supreme Court but was unsuccessful. TPR then issued a contribution notice (CN) for the scheme's full buy-out deficit. This was the first time TPR had used its powers to issue a CN in respect of a failure to comply with an FSD.
TPR agreed to a settlement with ITV, the scheme trustees and the PPF. Under the deal, all 2,800 members of the scheme have transferred to the ITV Pension Scheme and members who have been receiving benefits at PPF compensation levels since 2014 will receive full benefits and back payments.
TPR highlights that the case shows that it will pursue complex and lengthy litigation to protect savers and that it will remain open to settlement discussions at any time and will accept a settlement offer when it achieves a good outcome for the scheme.
Read the regulatory intervention report.
ECCTA: Identity verification requirements to take effect November 18
Regulations have been made bringing certain sections of the Economic Crime and Corporate Transparency Act (ECCTA) into effect. This includes confirmation that identity verification requirements for company directors, people with significant control (PSCs) and LLP members will come into effect on November 18, 2025, as anticipated. Separate regulations have been made to amend various pieces of legislation as a consequence of ECCTA.
Read the commencement regulations and the modification regulations.
PDP: One year to final dashboards connection deadline
The Pensions Dashboards Programme (PDP) has released a video marking that there is now less than one year until the final deadline for connection to the pensions dashboards ecosystem (October 31, 2026, though most schemes will need to connect before that date, in line with their staging deadline). The video comments on the project's progress: over 50 million pension scheme memberships are now connected to the ecosystem, representing around two thirds of the total number to be connected. It encourages a continuation of this momentum, to make sure that those that haven't connected will be ready to, in line with the staging timetable. It encourages schemes to approach the PDP for help where needed.
ICO consultation on data protection enforcement guidance
The Information Commissioner's Office (ICO) is consulting on draft updated statutory guidance on investigations and enforcement under the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018. It covers the full process of an investigation and enforcement action, including information-gathering, limits on powers (such as privilege), decision-making and appeals. It is intended to give more detail and transparency than previous guidance. It does not cover the process in relation to the prosecution of criminal offences. The consultation closes on January 23, 2026.
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