- in United Kingdom
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Welcome to our monthly update on current legal issues for trustees of DC 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 have a separate update for DB/hybrid schemes.
Finance Act receives Royal Assent
The Finance Act 2026 has received Royal Assent. The Act will bring most pension benefits into the scope of inheritance tax (IHT) from April 6, 2027. This will require schemes to have new processes for calculating relevant benefits; communicating with personal representatives (PRs); withholding payment of benefits; and paying tax directly. The government has confirmed that it will consult on regulations on exchange of information between PRs and pension schemes this spring and further guidance and tools will be provided by spring 2027.
Action: Schemes should start preparing for significant changes needed to comply with the new IHT requirements.
New data complaints processes
Most of the provisions of the Data (Use and Access) Act 2025 (DUAA) have now been brought into force. These changes include a requirement for data controllers to have a process in place to deal with data protection-related complaints from June 19, 2026. This includes: a complaint form that can be completed electronically; acknowledging receipt of a complaint within 30 days; responding to the complaint without undue delay; and communicating the new right to complain in privacy notices and SAR responses. The ICO has published guidance to assist data controllers.
Action: Ensure appropriate processes are adopted to identify and respond to complaints in line with these requirements; and review privacy notices and other communications.
Family leave changes
A number of changes are being made to family leave, including introducing a new entitlement to bereaved partner’s paternity leave.
Action: Review rules to confirm whether changes are needed; schemes and employers should make sure family leave policies and procedures reflect these updates.
DC scale requirements and consolidation guidance
The DWP and the Pensions Regulator (TPR) have produced tandem guidance on the upcoming requirements for DC multi-employer AE schemes to operate a main scale default arrangement holding at least GBP25 billion in assets by 2030. TPR has also published a blog post encouraging smaller DC schemes to consider whether continuing to run on is realistic, alongside consolidation guidance and updated winding-up guidance.
Action: Affected schemes should consider the guidance in their preparations for compliance.
TPR updates on dashboards compliance
TPR has updated its guidance on reporting breaches of the law to include two dashboard-related examples of “green breaches.”
Action: Consider the guidance as part of dashboards compliance projects.
Updated master trust reserving guidance
TPR has updated its guidance around regulatory capital reserving requirements for master trusts.
Action: Master trust clients should consider the new guidance.
TPR warning on impersonation fraud
TPR has issued a scam alert setting out steps that schemes should take following a significant increase in impersonation fraud targeting pension savers.
Action: Review the alert and implement the actions recommended by TPR.
Watch this space
- The government is developing guidance for trustees on their fiduciary duties, aimed at supporting trustees in considering factors including systemic risks (such as climate change) and members’ standards of living.
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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