UK Pensions: DC Trustee Agenda Update—October 2026

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This monthly update examines critical developments affecting DC pension scheme trustees, including HMRC's latest guidance on inheritance tax changes for pension benefits, implementation timelines for the Pension Schemes Act 2026, and new reporting requirements for pensions dashboards. The update also highlights ongoing consultations on small pots consolidation and auto-enrolment contribution increases that could reshape the DC pensions landscape.

United Kingdom Employment and HR

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.

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 an outline of upcoming HMRC guidance and materials.

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

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 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 and how to prepare.

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

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.

Have your say

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 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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