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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 consults on rules to clarify GMP conversion, including survivor benefits, employer consent and actuarial certification; completed conversions are unaffected.
- DWP proposes no change to fixed rate revaluation for GMPs for April 6, 2027 to April 5, 2032.
- PASA’s toolkit helps schemes monitor how pensions dashboards affect member behaviour and operational demand.
- Pensions Academy Online returns on September 29 and October 1, 2026, with a UK legal update and a session with TPR's Cliodhna Judge exploring AI's opportunities and risks and the regulatory expectations for UK pension schemes: sign up to join us.
Government consults on updates to GMP conversion rules
The Department for Work and Pensions (DWP) is consulting on draft regulations for GMP conversion (the process by which formerly contracted-out occupational schemes convert guaranteed minimum pension (GMP) benefits into other scheme benefits). The DWP proposes to clarify existing regulations in some respects—in particular, to help schemes choosing conversion to equalise benefits for the impact of historic GMP rules. The draft regulations:
- Clarify how survivor benefits must be treated as part of a conversion exercise, including simplifying the circumstances in which survivors’ pensions are paid after conversion and the period of payment.
- Define the “relevant persons” whose consent must be obtained for conversion—for example where the sponsoring employer at the time the GMPs were accrued no longer exists. The aim is to remove uncertainty for trustees: the draft regulations provide that the ‘relevant persons’ are the scheme’s statutory employers at the time of conversion.
- Remove the requirement to notify HMRC of the conversion exercise.
- Set out a new process to certify that pre- and post-conversion benefits are actuarially equivalent when a single individual’s GMP is being converted (for example at retirement). As an alternative to requiring an actuarial certificate for each individual conversion, it is proposed that the process (rather than the outcome) could be certified, with the model and assumptions reviewed and certified annually.
The changes would not apply to conversions that have been completed prior to the regulations coming into effect and do not call into question conversion exercises where consultation has started prior to that date. The consultation closes on October 29, 2026.
Read the GMP conversion consultation.
Government consults on GMP revaluation rates
The DWP is also consulting on maintaining the current 3.25% rate of revaluation which applies where schemes use fixed rate revaluation of GMPs for early leavers. The rate is reviewed every five years and if confirmed, would apply to formerly contracted-out members who leave pensionable service between April 6, 2027 and April 5, 2032, for the revaluation of their GMP benefits until they become payable. The consultation closes on October 29, 2026.
Read the GMP revaluation rates consultation.
PASA: Toolkit on monitoring trends following dashboard use
PASA has published a new toolkit to help trustees and others to monitor changes in member behaviour once pensions dashboards become available. PASA’s earlier Compliance Monitoring Guidance looks at the ongoing monitoring required to ensure that trustees are meeting their regulatory duties. The latest guidance focuses on the wider behavioural and operational implications of pensions dashboards. Monitoring is voluntary but could assist in identifying, for example, increases in demand for retirement or transfer quotations and payments.
Read the Dashboards Toolkit: Post Use Behaviour guidance.
Pensions Academy Online: Tuesday, September 29 and Thursday, October 1, 2026
Our next Pensions Academy Online sessions will take place on Tuesday, September 29 and Thursday, October 1, 2026. Each webinar begins at 9:30am and will last approximately one hour. We will be covering:
Legal update—Tuesday, September 29, 2026
Our regular round-up of all the latest developments in the legal corner of the occupational pensions world.
AI: the good, the bad and the future—Thursday, October 1, 2026
We are thrilled to welcome Cliodhna Judge, TPR's external market oversight lead for emerging governance topics, including cyber and AI, for a session exploring what artificial intelligence means for UK pension schemes. Cliodhna will join Francesca Parnell, counsel at A&O Shearman, to explore the opportunities, risks and regulatory direction of travel. Expect insights on where AI can help your scheme and members, the risks to watch out for, and what TPR expects from schemes today and into the future.
Click here to register for either or both sessions.
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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