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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
- DWP and TPR publish guidance for DC schemes on preparing for upcoming scale requirements.
- TPR asks schemes to take action in relation to impersonation fraud.
- PDP: blog post on pension status categories displayed to dashboards users.
- Plus: clarification being sought on upcoming data protection requirements; and annual Pensions Increase Review order published.
Guidance on upcoming DC scale requirements
The DWP and The Pensions Regulator (TPR) have produced tandem guidance on the requirements in the Pension Schemes Bill for DC multi-employer auto-enrolment schemes to operate a main scale default arrangement (MSDA) holding at least GBP25 billion in assets from 2030.
For schemes unable to meet that threshold by 2030, the government has established two additional routes: (i) a transition pathway—available to schemes holding at least GBP10bn in their MSDA by 2030 that can demonstrate a credible plan to reach GBP25bn by 2035; and (ii) a new entrant pathway—enabling new schemes to enter the market and grow to scale, provided they offer a materially different product compared to existing participants. The DWP guidance outlines considerations for schemes wanting to use these pathways.
TPR's guidance builds on the DWP's paper and gives more detail on how master trusts should prepare for the scale requirements. It sets out some of the areas it expects to see in a credible growth plan: for example forecasts, assumptions and growth factors.
Read the DWP paper and TPR's statement.
TPR urges action following rise in impersonation fraud
TPR has issued an urgent scam alert to pensions industry professionals warning of a significant increase in impersonation fraud targeting pension savers. The alert highlights that fraudsters are obtaining savers' personal information to breach security checks and access pension accounts. Criminals then change bank details or create fraudulent duplicate accounts to divert retirement savings. Analysis of reports to Report Fraud reveals that UK pension scheme members residing in Africa face heightened risk, though similar risks apply across all jurisdictions.
TPR and City of London Police are urging trustees and administrators to review identity verification procedures, strengthen data security for overseas correspondence, encourage members to adopt two-step verification and stronger passwords, and report any suspected fraud to Report Fraud immediately.
Dashboards: blog post on pension status categories
The Pensions Dashboards Programme (PDP) has published a blog post on the different pension status categories that will appear on the Moneyhelper dashboard. The categories are:
- "confirmed pensions" (reflecting a successful match with a scheme/provider)
- "pending pensions" (where the scheme/provider needs more time to provide the user's data)
- "pensions that need action" (where the user needs to provide more information or contact the provider).
The blog post outlines what information the user will receive in each case and the implications for pension schemes.
Data (Use and Access) Act: privacy notice requirements
We reported recently on the publication of the ICO's guidance in relation to the upcoming data protection complaints process requirements. We are seeking clarification of certain inconsistencies in the guidance and will report once the position has been made clear.
Annual Pensions Increase (Review) Order published
The Pensions Increase (Review) Order 2026 specifies the rate of annual increase for official pensions (such as ministerial and civil service pensions) and is also used as a reference point for indexation rules in some private sector schemes with a public sector history. The latest order sets the increase at 3.8% for pensions that began before April 7, 2025. The Order comes into effect on April 6, 2026.
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.
