This month’s insight covers the continued passage of the Pension Schemes Bill through Parliament, the Pensions Regulator’s (TPR) new defined contribution (DC) consolidation guidance and its dashboards updates and HMRC’s latest Newsletter which provides early insight into the intended operation of the transitional regulations that will support the increase in normal minimum pension age from 55 to 57 in April 2028.
Pension Schemes Bill: where ping pong has now landed
As at the date of writing, the Bill remained in ‘ping pong’, where it goes between the two Houses until the final sets of amendments are agreed. Key points from this stage of the Bill include the following.
Summary: The House of Commons stood firm on its core policy positions following further Lords’ consideration on 20 April 2026 and, on 22 April 2026, rejected the Lords’ latest amendments across the main areas of disagreement, but with concessions and refinements designed to allay the Lords’ concerns. Both the Commons and the Lords were due to consider the Bill again on 27 April 2026.
DC asset allocation power: Perhaps the most anticipated of the points was how the Commons would address the Lords’ removal of the Government’s ability to make regulations on the percentage and type of qualifying assets that default DC funds must hold. It did so by reinstating the regulation-making mandation power but with restrictions that track the Mansion House Accord and, following the Lords’ subsequent rejection of the reinstated clause, changing the time-limited nature of the power which has not yet swayed the Lords. As at 26 April 2026, the provision had been amended in the following way:
- Qualifying asset description: the regulations must describe qualifying assets for each category, providing greater clarity on eligible investments;
- Capped percentages: asset allocation limits have been included so that the Government cannot require more than 10% of the value of a default fund to be held in qualifying assets and 5% (by value) held in UK-specific assets (either located in the UK or linked to UK economic activity); and
- Time restrictions: the longevity of the mandation framework has been limited so that the regulation making power can be exercised only once, and with the asset allocation regime being subject to an automatic statutory repeal - falling away at the end of 2032 if unused, and in any event, being repealed by the end of 2035.
DC scale requirements and consolidation: The Lords proposed a revised exemption from the DC scale requirements where TPR considers consolidation would not enhance outcomes or where innovation is already delivering good member outcomes. The Commons rejected this, instead coming up with a new Secretary of State reporting requirement on the impact of consolidation on innovation in the design and operation of master trusts and Group Personal Pensions (GPPs). The extent to which competition and innovation must be considered when making regulations on scale and quality were addressed by the Commons through provisions which would require consideration of these matters and others when making regulations.
Public service pension schemes: Finally, the Commons replaced the Lords’ proposed wide ranging review of public service pensions with a more limited actuarial measure. Under the revised provisions, the Government Actuary must publish 50 year cash flow projections for certain defined benefit public service pension schemes within 12 months of the provision coming into effect. The scope is deliberately limited and does not extend to local government pension schemes.
The pensions regulator (TPR)
DC: new consolidation guidance and reworked winding up guidance
As part of its drive to get smaller DC schemes (typically fewer than 5,000 members) to consolidate where appropriate, TPR has published new consolidation guidance for trustees thinking about transferring to a master trust which should be read alongside its reworked winding up/ transferring guidance.
As with other trustee decisions, deciding whether to transfer, involves considering relevant factors – TPR believes these include:
- thinking about regulatory landscape evolution - as part of the value for members consideration, and, considering the new guided retirement and small pots requirements when they come into force;
- costs;
- regulatory priorities for trusteeship – having a well-run and well governed scheme with high administration and data standards and being resilient to risks such as cyber ones; and
- member needs such as an appropriate default fund and adequate support throughout the member experience.
TPR goes on to discuss the benefits of a master trust, compliance with Pension Schemes Bill requirements, innovative member communication and engagement strategies, and solutions for arrangements with attaching guarantees or benefits such as ‘with profits’. The guidance sets out questions that trustees may ask as part of their master trust due diligence and the additional factors that hybrid scheme trustees will need to think about. Finally, it directs trustees to TPR’s winding up/ transfer guidance which takes trustees through the three stages of winding up; (1) deciding on wind up; (2) preparing to start formal wind up; and (3) completing the wind up.
Dashboards
TPR dashboards blog reports on its market oversight report and updated guidance
With just six months to go until the final connection deadline of 31 October 2026 and 75% of records already connected, TPR has published a timely reminder that connecting to pensions dashboards is only the first step. The success of dashboards depends not just on connection but also on schemes being able to correctly match users to schemes records and return correct and up to date data to members within statutory deadlines.
Alongside its blog, TPR also published its findings into its large occupational scheme dashboards engagement initiative and updated dashboards guidance.
Key messages from TPR
TPR’s engagement with the 51 largest occupational schemes (covering over 80% of in scope records) highlighted clear examples of good practice, but also variation in approach and advancement, particularly around value data which trails behind personal data.
Value data, the key risk area: TPR’s strongest message is that value data has not been progressed as much as personal data. Material value data work is still required, particularly for defined benefit and hybrid schemes, where values may not be refreshed regularly.
Learning from live user testing: The Money and Pensions Service’s (MaPS) testing of the MoneyHelper dashboard is now ‘ramping up’ and feedback so far has been positive, albeit there have been issues. TPR encourages schemes to treat this phase as a useful opportunity to test their capabilities ahead of full public availability.
Updated TPR dashboards guidance – what’s changed?
TPR has updated its dashboards guidance to reflect developments and ‘learnings’ including good practice, progress made by MaPS (including its latest guidance), and to make FAQ areas clearer. There are now two checklists (rather than one) covering before and after connection.
What TPR expects of schemes going forwards
TPR expects trustees and scheme managers to receive regular, meaningful reporting from providers, and to resolve issues. Schemes that are not connected by 31 October 2026 should expect engagement from TPR, and wilful or reckless non compliance may lead to enforcement action. TPR is going to contact defined benefit (DB) and hybrid schemes during May 2026 to find out how they are preparing value data.
TPR updates its reporting breaches of law guidance to include two dashboard examples of ‘green breaches’
TPR has updated its reporting breaches of law guidance to provide two examples of ‘green breaches’ (that are not likely to require reporting) in a pensions dashboards context. These include a brief annual delay in updating DB values while data is transferred between systems, and a short term use of older deferred member values during the dashboards testing phase where mitigations and future process changes were in place. In both cases, TPR highlights the limited duration, low member impact and proportional trustee response. In the second example, TPR warns that longer lasting or post launch failures could be treated differently.
HMRC: Newsletter 180 provides background on scope and intended effect of NMPA transitional regulations
HMRC’s Newsletter 180 provides ‘early background’ on the transitional regulations that will ‘support’ the increase to normal minimum pension age (NMPA) from 55 to 57 on 6 April 2028 and ensure affected members who have reached age 55 on or before 5 April 2028 but who have not reached age 57 by 6 April 2028 (a NMPA Member) can carry on receiving benefits without ‘interruption’. The Newsletter provides examples of the treatment of pension and various lump sum payments alongside confirmation of the position in respect of the transfer of pension payments.