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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
- TPR publishes finalised enforcement approach setting out high level principles.
- PASA publishes industry guidance on assessing operational readiness for guided retirement.
- 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, risks and the regulatory expectations for UK pension schemes: sign up to join us.
TPR revised enforcement approach
The Pensions Regulator (TPR) has published a new enforcement approach, alongside a response to last year’s consultation on the new strategy. The majority of the draft approach has been retained. It is intentionally high level, to give TPR flexibility as new risks and priorities emerge. In response to feedback that more detail and examples would be helpful, more specifics will be provided in underlying enforcement policies and guidance.
The approach is intended to align with TPR’s aim to be proportionate, risk-based and outcome-focused. Enforcement priorities will be based on an assessment of impact, scale and complexity; the consultation response gives more detail on how those criteria will be applied. Other key themes include commitment to early engagement; taking decisive action where necessary; and enhanced transparency to influence behavior, raise standards and build trust.
TPR will implement the approach through a phased program of work. This includes reviewing its internal processes, policies and governance, as well as its externally published materials, starting with high-impact areas.
Read TPR’s new enforcement approach and consultation response.
PASA guidance on delivering guided retirement
The Pensions Administration Standards Association’s (PASA) DC Working Group has published guidance aimed at helping schemes begin to prepare for guided retirement. Guided retirement requirements are expected to be phased in from summer 2029, meaning that occupational DC schemes will have to provide members with one or more default decumulation solutions designed to provide a regular income in retirement. PASA acknowledges that schemes cannot build their final guided retirement solution now, as more details of the requirements are awaited, but they can begin assessing operational readiness. The guidance focuses on four key areas: systems, data, governance and member communications and includes a readiness checklist.
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.
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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