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.
TPR annual funding statement
The Pensions Regulator (TPR) has published its latest annual funding statement. Although targeted at schemes with valuation dates between September 22, 2024 and September 21, 2025, it includes important information for all occupational DB schemes. It sets out guidance on: applying the new DB funding regime (focused on covenant assessment and monitoring, and supportable risk); approaching scheme surpluses; and considerations in relation to macroeconomic uncertainty.
Action: Review the guidance and take any relevant recommended actions.
TPR supervision of professional trustees
TPR has announced that it will be extending its oversight of professional trustee (PT) firms. It will begin targeted engagement with larger PT firms in the summer, extending its approach to cover remaining firms by the end of the year. It will use this process to identify risks and appropriate mitigations and expectations.
Action: Professional trustees should prepare to be contacted by TPR and questioned on the key focus areas.
TPR guidance on market volatility
TPR has published a market oversight report setting out guidance for trustees on preparing for and responding to market volatility in light of recent trade and geopolitical tensions. It sets out best practice actions for trustees of DB and DC schemes.
Action: Review the guidance and consider which actions are relevant to your scheme.
Dashboards: standards, DPIAs and guidance on split administration
The Pensions Dashboards Programme (PDP) has published updated versions of the standards that schemes—or administrators/integrated service providers (ISPs), where they are facilitating dashboards connection—must comply with for dashboards connection.
The PDP's data protection impact assessment (DPIA) for processing in relation to the central dashboards architecture is now available. DPIAs in relation to dashboards processing activities at scheme level are the responsibility of the scheme trustee as data controller.
The PDP has also published a blog post setting out guidance on dashboards connection via a third party and a progress update report. Guidance from PASA includes reassurance from TPR for schemes with split administration (e.g. a separate AVC provider) that cannot connect all benefits on the same date.
Action: Ensure your scheme/administrator/ISP is on track for complying with the standards in time for your dashboards connection deadline. Complete a DPIA for your scheme's dashboards processing.
Upcoming rules on identity verification and corporate filing
Changes under the Economic Crime and Corporate Transparency Act (ECCTA), intended to prevent the use of corporate entities for criminal purposes, are being brought in gradually. By autumn 2025, identity verification is expected to be compulsory for new directors and Persons with Significant Control (PSCs); there will be a 12-month transition phase for existing directors and PSCs. Companies House has launched a service allowing individuals to verify their identity voluntarily. From spring 2026, new restrictions on who can file documents at Companies House on behalf of companies are expected.
Action: Corporate trustees should keep a watching brief and begin identifying procedures which will need updating. Consider whether you wish to voluntarily verify identities ahead of mandatory requirements. Read more on the Economic Crime and Corporate Transparency Act 2023.
Finance Act 2025 comes into effect
The Finance Act 2025 has received Royal Assent. In relation to pensions, the act brings requirements for recognised overseas schemes in the EEA and Gibraltar in line with the rest of the world. It also requires scheme administrators (for tax purposes) of UK registered schemes to be UK resident.
Action: Ensure that administrative processes (for example in relation to overseas transfers) have been updated for the changes.
Watch this space
- The forthcoming Pension Schemes Bill is expected before Parliament's summer recess. It is due to cover measures including the automatic consolidation of deferred DC small pots, the introduction of a standardised Value for Money test for DC schemes and the framework for commercial DB consolidators (superfunds). It will also introduce duties for trustees to offer decumulation options to members and remove the need for pension schemes to apply to the County Court to enforce the recovery of an overpayment following a TPO decision.
- Following November's Mansion House Speech, the government published an interim report on its Pensions Investment Review, with a consultation on proposals for accelerating consolidation in the DC market. The key proposal is that master trusts and GPPs used for auto-enrolment should have a maximum number of defaults of a minimum size. The government is also seeking views on new duties for employers to consider the value provided by pension arrangements. These measures may be included in the upcoming Pension Schemes Bill. The Pensions Minister has announced that the final report on the Review will be published in the coming weeks.
- The government intends to consult on trustee accreditation and governance later this year.
- There is currently no date for revised regulations on changes to the notifiable events regime.
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.
