UK Pensions: Joint DB And DC Trustee Agenda Update—October 2026

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HMRC has issued further guidance on inheritance tax changes affecting pension benefits from April 2027, while the Pensions Dashboards Programme confirms revised reporting timelines and the government publishes detailed proposals for implementing the Pension Schemes Act 2026. Multiple consultations are now open covering GMP conversion, small pots consolidation, and auto-enrolment contribution increases.

United Kingdom Employment and HR

Welcome to our monthly update on current legal issues for trustees of DB and hybrid 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 also have a separate DC-only briefing.

Inheritance tax and pensions—further HMRC guidance

HMRC has published a second technical note on the upcoming changes bringing most pension benefits into the scope of inheritance tax (IHT) from April 2027. The note focuses on information sharing between personal representatives and pension scheme administrators. It also includes a timeline of upcoming HMRC guidance and materials.

Action: Ensure your administrative processes and governance are ready for the IHT changes.

TPR: dashboards updates

The Pensions Dashboards Programme (PDP) has confirmed a revised timetable for new daily dashboards reporting requirements. Organisations that have not yet implemented daily reporting will be required to submit some key metrics manually (via file upload) until implementation is complete. The PDP has published guidance on how to report manually commencing in October (for September 2026 data).

Action: Ensure you are prepared for the reporting requirements.

Pension Schemes Act—details of proposals and timing

A revised roadmap setting out timelines for the implementation of the changes in the Pension Schemes Act 2026 has been published, alongside various related documents:

A policy paper and draft legislation to allow direct surplus payments to members to be treated as authorised for tax purposes.
A consultation on the Value for Money framework. TPR has published overviews of the framework and proposed digital solution.
A DC scale requirements discussion paper.
Principles for guided retirement.
TPR has published a new web page summarising the changes introduced by the Act and how to prepare.

Action: Most areas require a watching brief for now, pending regulations.

Have your say

The DWP is consulting on draft regulations clarifying uncertainties in the current legislation on GMP conversion (the process by which formerly contracted-out occupational schemes convert guaranteed minimum pension (GMP) benefits into other scheme benefits). The consultation closes on October 29, 2026.
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 consultation closes on October 29, 2026.
The government is consulting on a framework for consolidating small, deferred DC pension pots into consolidator schemes. The aim is to have this system in operation from 2030. The consultation ends on November 17, 2026.
The Work and Pensions Committee has launched an inquiry looking at auto-enrolment, including whether contributions should increase and, if so, how that should be split between employers and employees. The deadline for responses is October 26, 2026.
The government is consulting on modernising the UK’s corporate reporting framework, proposing a wide-ranging overhaul of financial, non-financial and corporate governance reporting requirements. The consultation closes on November 30, 2026.

Watch this space

The government intends to consult on issues around transfer advice.
The government is developing guidance for trustees on their fiduciary duties.
The Pensions Minister of State recently announced that the government intends to review the legislation around Flexible Apportionment Arrangements (FAAs) “in due course”.

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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