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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.
Summary
- TPR analysis models a significant shift in the DB landscape over the next decade.
- TPR publishes data and commentary on decumulation offerings in occupational DC schemes and encourages trustees to start preparing for the guided retirement duty.
- HMRC's latest Pension Schemes Newsletter includes updates and reminders on protected pension age changes from April 6, 2028.
- Plus: MaPS seeks dashboards testers and PASA publishes guidance on the trustee-administrator lifecycle.
TPR: DB schemes over the next decade
The Pensions Regulator (TPR) has published analysis modelling how the occupational DB pension scheme universe may evolve over the next decade. The research highlights a “paradigm shift” in DB funding. Key findings include:
- Buy-out readiness: Over 75% of schemes (more than 3,400) could be in a position to buy out without additional employer contributions by the end of the decade.
- Insurance market capacity: TPR expects that the bulk annuity market will be able to absorb all schemes wishing to buy out over the next ten years, though short-term pressures may arise.
- Surplus distribution: Buy-out surplus is projected to reach approximately GBP120 billion over the decade, requiring decisions from trustees and employers on how and when to access it.
- Open schemes: Ongoing funding surpluses could meet GBP30bn of accrual costs for schemes still open to new entrants.
- Superfunds: The development of superfunds would not affect the bulk annuity market over the short term, as there are excess numbers of schemes which are sufficiently funded and want to insure all benefits.
TPR analysis: DC decumulation products and tailoring default options
TPR has also published analysis of the occupational DC market in advance of the introduction of the guided retirement duty in the Pension Schemes Bill. The data, taken from 2025 DC scheme returns, shows that 16% of schemes (master trusts and larger schemes covering 43% of all DC members) offer drawdown as a decumulation product—but at the other end of the scale, 43% of schemes representing 1% of DC members offer no decumulation options at all.
The report notes that as the in-scheme decumulation market evolves, terminology or interpretation may change. In this report, products were categorised into three broad classifications—one-off or partial withdrawals such as uncrystallised funds pension lump sums; annuity-related products and ‘regular income in-scheme products' including drawdown and using DC assets to purchase a pension in-scheme.
The Regulator's message is that trustees should start to think about what their decumulation offering under the forthcoming guided retirement duties might look like—and smaller schemes that are not able to provide appropriate options should consider consolidating into a scheme that can.
Linked to this, TPR has published a blog post discussing how default options could be more tailored to reflect different savings journeys. The post highlights that career breaks—particularly those taken early in working life for caring responsibilities—can reduce retirement pots by around 16%, with women disproportionately affected. It argues that, to help address this, trustees could use existing member data (contribution histories, pot sizes, age profiles) to identify cohorts likely to have similar circumstances and consider modest differentiation in default designs. This could involve different glidepaths, guardrails, and potentially different income smoothing mechanisms.
Read the press release, report and the blog post.
HMRC: Latest pension schemes newsletter
HMRC has published its latest pension schemes newsletter (no. 178). It provides an update on transitional regulations for the implementation of the increase to the normal minimum pension age from age 55 to age 57 from April 6, 2028, saying work on the regulations is “ongoing”, with further details to be shared once the draft transitional regulations are ready for technical consultation. It also discusses the rules on retaining a protected pension age (PPA) following a transfer to another pension scheme and suggests that where PPA details attached to previous transfers have not been shared with receiving schemes, consideration should be given to sharing this information retrospectively so that accurate data is held ahead of the change.
In relation to changes bringing pension benefits into the scope of inheritance tax from April 6, 2027, the newsletter notes that further information and detailed guidance will be published “in due course”. It also includes sections on new requirements to report a transfer to a qualifying recognised overseas pension scheme (QROPS) through the managing pension schemes service; delays to new systems for relief at source; and the protection look up service.
Read the Pension Schemes Newsletter.
MaPS asks schemes to help find dashboards testers
The Money and Pensions Service (MaPS) is recruiting testers for phase 2 of consumer testing of the MoneyHelper Pensions Dashboard. Trustees and employers are encouraged to contact members and employees to highlight this opportunity to be involved in testing. Organisations wishing to help recruit testers can register to receive a toolkit.
Anyone aged 18 or over who has not yet started withdrawing all their pensions can participate. MaPS is particularly seeking assistance from the pensions industry to involve individuals with access needs or confidence barriers around literacy, numeracy, digital skills and technology.
PASA: Trustee-administrator lifecycle guidance
The Pensions Administration Standards Association (PASA) has published the first in a four-part series of guidance on the trustee-administrator life cycle. This first part sets the context, explaining why strong trustee-administrator relationships are fundamental to effective scheme governance.
The guidance is intended to support all types of trustees in working effectively with their administrators. It promotes shared understanding of administration delivery, clearer reporting and greater awareness of the operational challenges faced by service providers.
Subsequent instalments will cover appointing a new administrator, managing installation and transition, and building, measuring and maintaining effective partnerships.
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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