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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.
HMRC: details on IHT changes
HMRC has published a technical note giving more details on the application of inheritance tax (IHT) to pensions and a consultation on draft regulations for the exchange of information between PRs and pension schemes is now under way. Further guidance and tools will be provided by spring 2027. Our briefing provides an overview of the changes.
Action: Start preparing for significant changes needed to comply with the new IHT requirements.
Pension Schemes Act receives Royal Assent
The Pension Schemes Act 2026 has received Royal Assent, laying the groundwork for a range of significant changes to the UK pensions landscape. The Act includes legislation for a new DC Value for Money framework and for the consolidation of small, dormant DC pots; requirements for master trust and GPP main scale default funds; the framework for guided retirement solutions; and more.
Action: Most areas require a watching brief for now, pending further regulations.
New guide for DC wake-up packs
The Money and Pensions Service (MaPS) has published a redesigned guide to be included in ‘wake-up’ packs for DC members.
Action: Include the new guide in wake-up packs.
Company accounts reforms
The government has announced that accounts reforms will come into effect from April 2028. These include: requiring filing of profit and loss accounts; requiring use of commercial software; removing the option of abridged accounts; a strengthened eligibility statement for companies claiming an audit exemption; and changed filing requirements.
Action: Corporate trustees should review whether they are impacted by the changes.
TPR publishes AI plan
TPR has published an AI plan, outlining expectations for the adoption and governance of AI in workplace pension arrangements. TPR expects trustees and administrators to establish robust governance and accountability for their own, and providers’, use of AI systems and technologies; to understand how AI models use and process data, and to seek advice when required.
Action: Read the AI plan and consider the implications for your scheme. More detailed guidance is to follow.
TPR: dashboards updates
TPR has updated its dashboards guidance to answer common questions and highlight best practice and has provided two checklists to help schemes prepare for dashboards duties. TPR has also updated its guidance on reporting breaches of the law to include two dashboard-related examples of ‘green breaches’. It has been confirmed that the ‘go live’ date for dashboards is likely to be in financial year 2027/28.
Action: Consider the guidance as part of dashboards compliance projects.
Have your say
- The DWP has published a consultation on proposed amendments to the regulations setting out the red and amber flag system for pension transfers. The consultation closes on July 21, 2026.
Watch this space
- The government is developing guidance for trustees on their fiduciary duties.
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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