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We have published a guide to the "landmark" Pension Schemes Act, including expected implementation dates and links to relevant sections.
The content is based on the Act as published in May 2026 and the Government's August 2025 roadmap.
DB schemes
Local Government Pension Scheme
Regulations may make provision as to asset pool companies under the Local Government Pension Scheme, and the participation by schemes in asset pool companies.
The regulations must make provision about the management of relevant assets, including requirements for assets to be held by asset pool companies, and for scheme managers to adopt an investment strategy and to co-operate with local authorities as to investment opportunities.
Regulations may also make provision for governance reviews of scheme managers.
Existing regulation-making powers are amended so as to cater expressly for the merger of schemes within LGPS.
Refunds from ongoing schemes
Trustees will have power to modify schemes by resolution, to give themselves refund powers or to remove restrictions on existing refund powers.
Conditions for refunds will be prescribed, including a funding test.
Current conditions as to "s.251 resolutions" and "interests of members" will be repealed.
Virgin Media remediation
DB schemes which were contracted-out on the salary-related basis
In force from 29 April 2026
Trustees can validate (remediate) historic amendments which might otherwise be void on Virgin Media grounds, if they obtain retrospective actuarial confirmation.
For remediation purposes, the scheme actuary must confirm that the relevant amendment would not have prevented the scheme from continuing to satisfy the contracting-out "reference scheme test".
There are limited carve-outs: an amendment may not be remediable if it has been the subject of "qualifying legal proceedings" before 29 April 2026 (when the Act received royal assent), or if the trustees have taken "positive action" on the basis that it was invalid.
For schemes which were wound up or fell into the PPF before 29 April 2026, amendments (save as above) are deemed to have been valid on Virgin Media grounds, without the need for retrospective confirmation.
Superfunds
Superfunds; ceding DB schemes
April 2028
Superfunds will be subject to authorisation by TPR.
New requirements will apply as to the operation of superfunds, covering governance and structure; funding and investment; key personnel; and information and reporting. Special requirements and TPR powers will apply if an "event of concern" occurs.
Superfund transfers will be subject to TPR's approval. "Onboarding conditions" will need to be met, including (unless a scheme is exiting PPF assessment) the following:
- the ceding scheme's funding is not strong enough to enable a full buy-out, at the point when approval is sought; and
- the transfer will make it more likely that liabilities will be met in full.
Click here to download our overview of the Act
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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