In this “back to school” issue, we explore the latest developments under the Pension Schemes Act 2026 reforms and share our latest thinking on the rapidly evolving use of artificial intelligence within pensions. We also cover a range of other issues that are likely to be high on the agenda this autumn, including pensions dashboards, the developing CDC market, proposed changes to SIPP rules and the forthcoming increase in NMPA.
We are also pleased to share recent industry recognition of Burges Salmon’s continued investment in pensions, with The Lawyer highlighting the firm’s strategic growth in the sector and the strength of our pensions practice.
We also examine the impact of AI on member IDRP complaints and provide details of our next AI and Pensions event – read on for more details.
PSA26 reforms
Surplus law changes: the employer perspective
We examine actions that sponsors of DB schemes should be considering now, ahead of the planned implementation of the surplus law changes under the PSA26, currently scheduled for April 2027.
Value for money changes
As we highlighted in July, TPR, the FCA and the DWP are currently consulting on the proposed value for money framework to be implemented under the PSA26. The consultation has been extended by two weeks and now concludes on 15 September 2026.
The consultation proposals are detailed and technical, with the paper running to some 193 pages. To assist trustees and independent governance committees, TPR has published an overview for trust-based DC schemes alongside a digital service technical overview document. The scheme overview is a useful summary of the provisions to help trustees digest the new requirements. The technical overview is designed as a practical digest of the proposed digital solution and is designed to allow schemes to start to prepare for the first round of data submissions in 2028.
Read scheme overview Read digital overview
Visit our PSA26 webpage
Did you know we have a dedicated webpage for the PSA26 reforms?
As well as the latest edition of our handbook (updated on 5 August 2026 to account for the latest publications from the DWP, TPR and HMRC), you’ll find timelines outlining key DB and DC milestones and a library of our thought leadership articles, all organised by theme for ease of navigation.
AI in Pensions
AI and IDRPs
With use of AI technologies becoming rapidly more widespread, we consider what impact this has on member IDRP complaints – and how trustees might need to adapt their approach in response.
AI, vulnerability and customer outcomes
In this article we consider the findings of a recent report by the Payments Association – “How AI-powered banking tools are failing vulnerable customers” – and identify practical tips for pension providers and financial services firms to improve outcomes for customers.
Burges Salmon and Quietroom: AI and Pensions – what works, what’s next?
If you are interested in finding about more about the impact of AI in pensions, there are still a handful of places available to join us at our London offices on Thursday 10 September 2026, for our joint event with communications experts Quietroom. We’ll be exploring who’s doing what, what’s working, and what’s round the corner – with plenty of practical insights throughout.
Dates for your diary
An invitation to join us for Pensions drinks in Bristol, Edinburgh and London
This Autumn we’re very pleased to be hosting a series of drinks events for clients and contacts across our offices. We’d be delighted if you’re able to join us for an informal evening of drinks, nibbles and networking in either Bristol, Edinburgh or London.
Whether you have known us for many years or are getting to know Burges Salmon for the first time, we’d love you to join us. Please follow the links below for further details and to RSVP.
Bristol
Wednesday 23 September
Edinburgh
Tuesday 17 November
London
Thursday 26 November
Policy round-up
Thought leadership
Further Update on Inheritance Tax Reforms: what do those running pension schemes need to know
7 September 2026
Thought leadership
Pension Under Saving in the UK: the EDI perspective on the Second Pensions Commission’s Interim Report
2 September 2026
Governance
April 2028 NMPA increase
Normal minimum pension age will increase from 55 to 57 on and from 6 April 2028. This means that the minimum age at which members can draw their benefits without them being taxed as unauthorised payments will be 57 (note, this does not prevent scheme rules specifying a higher minimum, or in some cases satisfying the conditions to retain a protected pension age of 55).
HMRC is currently consulting on draft regulations to implement transitional protections for members aged 55 or 56 who become entitled to their pension or a lump sum before 6 April 2028, but do not receive the first payment until on or after this date. The risk is that without transitional arrangements being in place such payments become unauthorised. The draft regulations set out proposed transitional measures designed to address this scenario.
The consultation closes on 28 September 2026.
Dashboards developments
With the final dashboards connection deadline looming large on the horizon next month, for many the focus has already turned from initial connection to ongoing compliance (including member matching and pension value data), user testing and preparations for
public launch.
In this article Andy Prater summarises key recent developments, including a helpful FAQ document published by PASA to assist schemes with answering member queries.
Pensions bites
Thought leadership
CDC: The Next Phase of UK Pension Reform
28 August 2026
Thought leadership
CP26/20 – A review of the FCA’s new proposed rules for SIPP providers
24 August 2026
Team news
We are delighted to welcome a number of new lawyers to our team across our Bristol, Edinburgh and London offices this month. Since 1 May 2024, we have recruited 29 lawyers across all levels and are the fastest-growing pensions legal team in the UK. Particular congratulations to Yadhavi Analinkumar, Kate Burgess, Zuzana Choteborska, Fahmida Rahman and Emily Williams, who have all completed their training contracts with us and join the team as solicitors. We are delighted to have you.
We have received very positive coverage of our pension team growth strategy in a recent The Lawyer article and are taking time to bond with and support our communities with a volunteering day today.
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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