UK Pensions: Joint DB And DC Trustee Agenda—December 2025

Welcome to our monthly update on current legal issues for trustees of DB and hybrid 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 also have a separate DC-only briefing.

Draft legislation forVirgin Mediaremedy

The government has published an updated draft of the Pension Schemes Bill, which includes provisions addressing issues following the Virgin Media decision (which held that certain amendments made by schemes that were contracted-out on a section 9(2B) basis between 1997 and 2016 are void unless a necessary actuarial confirmation was provided).

The drafting sets out a process under which schemes can (subject to conditions) remedy the voiding of an alteration for lack of confirmation. This will require an actuary to confirm that it is reasonable to conclude that the alteration would not have prevented the scheme from continuing to satisfy the statutory standard at the time. The FRC has announced that it will develop guidance to help actuaries giving these confirmations.

A High Court decision is expected shortly, which may further clarify the scope of the issues.

Action: Review any Virgin Media - related projects in light of these developments.

TPR: revised data guidance

The Pensions Regulator (TPR) has published revised guidance on member data. The guidance consolidates all previous data-related guidance into one place and is intended to set out clearer expectations (including best practice examples) to help schemes achieve better data management.

Action: Review the guidance and consider whether your scheme is complying with TPR's expectations.

New corporate identity verification and filing requirements now in force

Identity verification became compulsory for new directors and Persons with Significant Control (PSCs) of UK companies on November 18; existing directors and PSCs will need to verify their identity with their next annual confirmation statement. Verification will also be required for members of UK LLPs and directors of overseas companies that have a UK establishment.

There will also be changes to company register requirements and the information that needs to beprovided to Companies House in relation to PSCs.

Read more.

Action: Corporate trustees and any other corporate scheme structures must comply by the relevant deadlines. Voluntary verification ahead of the deadlines is encouraged by Companies House.

CDC regulations and consultation

The government has published a consultation response, draft regulations and a new consultation on Collective Defined Contribution (CDC) arrangements (where investments are held in, and benefits paid from, a collective fund, providing a non-guaranteed target annual income). The draft regulations expand the scope of the current CDC framework to allow unconnected employers to participate in a CDC arrangement. The new consultation looks at options to allow DC savers to transfer into a CDC scheme at retirement. This could provide a decumulation income option (in line with the forthcoming guided retirement framework).

Action: Consider whether CDC could be of interest to your scheme, in particular in light of upcoming guided retirement requirements.

Have your say

• The Pension Protection Fund (PPF) has published a consultation on its 2026/27 levy. It intends to maintain a zero levy for conventional schemes, but this is dependent on there being "a very high level of confidence" that provisions in the Pension Schemes Bill relating to the levy will be passed. The consultation closes on January 5, 2026.
• 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. The consultation closes on January 23, 2026.
• The government is consulting on options for retirement CDC schemes (see more above). The consultation closes on December 4, 2025.

Watch this space

• The government intends to consult on trustee accreditation and governance later this year.
• The Data (Use and Access) Act (DUA Act), which makes amendments to the UK General Data Protection Regulation and Data Protection Act 2018, has received Royal Assent. Changes include helpful tweaks to deadlines for responding to data subject access requests and new requirements around handling data protection complaints. Some regulations have been made bringing parts of the Act into force, but further regulations setting out details and bringing the remainder of the Act into force are awaited.
• There is currently no date for revised regulations on changes to the notifiable events regime.
• The government has confirmed that it intends to consult in the coming months on issues around transfer advice, potentially including the cost and availability of independent financial advice and the GBP30,000 threshold that triggers a requirement for independent advice on a DB transfer.