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.
New corporate identity verification and filing requirements from November 18, 2025
From November 18, 2025, identity verification will be compulsory for new directors and Persons with Significant Control (PSCs) of companies; existing directors and PSCs will need to verify their identity with their next annual confirmation statement (read more). There will also be changes to company register requirements (read more).
Action: Corporate trustees must comply by the relevant deadlines. Voluntary verification ahead of mandatory deadlines is encouraged by Companies House.
Draft legislation on pensions and IHT
Unused pension savings will be brought into the scope of Inheritance Tax (IHT) from April 6, 2027, although death in service lump sums and DB dependants' pensions will fall outside the scope of IHT. For more details, see ‘Have your say' below.
Action: The exact scope of the changes remains unclear in some aspects; contact your usual AOS adviser for further information.
Government to provide Virgin Media fix
The Government has announced that it will help with uncertainty following the Virgin Media decision (which held that certain amendments made by schemes that were contracted-out on a section 9(2B) basis between 1997 and 2016 are void unless a necessary actuarial confirmation was provided). The Government will ‘give affected pension schemes the ability to retrospectively obtain written actuarial confirmation that historic benefit changes met the necessary standards'. No further details are currently available. A High Court decision is expected shortly, which may further clarify the scope of the issues.
Action: Review the timing of any Virgin Mediarelated projects in light of these developments.
TPR endgame guidance
The Pensions Regulator (TPR) has published new guidance for DB schemes when deciding their endgame strategy. The guidance discusses runningon schemes and sharing surplus with employers, as well as a number of other endgame options.
Action: Take the guidance into account when considering endgame strategy.
Pension Schemes Bill 2025 published
The Pension Schemes Bill has been published, containing a raft of changes to the pensions landscape, including: easier release of DB surpluses to employers; a DC value for money framework; requirements for master trusts and GPPs to have a default fund with a minimum level of assets under management and potentially a prescribed level of investment in ‘productive assets'; a framework for consolidation of small, dormant DC pots; requirements for schemes to provide DC members with a guided retirement product; and a legislative framework for DB superfunds. Read more.
Action: Keep a watching brief as the Bill progresses and regulations are published. Arrange training on the aspects that affect your scheme.
Have your say
- The Government has published a consultation response, policy paper and draft legislation on bringing pensions into the scope of Inheritance Tax (IHT) from April 6, 2027. Key points to note are (a) death in service benefits will fall outside the scope of IHT; (b) personal representatives (not pension schemes) will be responsible for reporting and paying any IHT due; and (c) schemes will be subject to new duties, including a ‘scheme pays'- style mechanism for settling IHT bills. The draft regulations are open for consultation until September 15, 2025.
Pensions Academy Online: Tuesday, October 7, and Thursday, October 9, 2025
Our next Pensions Academy Online webinars will take place on Tuesday, October 7, 2025, and Thursday, October 9, 2025. Each webinar begins at 9.30am and will last approximately one hour. If you would like to attend, please register here.
We will be covering:
- Legal update – Tuesday, October 7, 2025: we'll round up all the latest developments and outline what's on the pensions horizon.
- Pensions 2030 and beyond: preparing now for the future landscape – Thursday, October 9, 2025: we're facing significant change across the UK pensions landscape and more could be coming. We'll look at the big picture from the perspectives of trustees, employers and members, to help you plot a route from here to there.
Watch this space
- The Government intends to consult on trustee accreditation and governance later this year.
- Regulations allowing multiple unconnected employers to establish a CDC scheme are expected in the autumn.
- The Data (Use and Access) Act (DUA Act), which makes amendments to the UK General Data Protection Regulation and Data Protection Act 2018, has received Royal Assent. Changes include helpful tweaks to deadlines for responding to data subject access requests and new requirements around handling data protection complaints.Some regulations have been made bringing parts of the Act into force but further regulations setting out details and bringing the remainder of the Act into force are awaited.
- 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.
