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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.
TPR: revised data guidance
The Pensions Regulator (TPR) has published revised guidance on member data. The guidance consolidates all previous data-related guidance into one place and is intended to set out clearer expectations (including best practice examples) to help schemes achieve better data management.
Action: Review the guidance and consider whether your scheme is complying with TPR's expectations.
CDC regulations and consultation
The government has published a consultation response, draft regulations and a new consultation on Collective Defined Contribution (CDC) arrangements (where investments are held in, and benefits paid from, a collective fund, providing an unguaranteed target annual income). The draft regulations expand the scope of the current CDC framework to allow unconnected employers to participate in a CDC arrangement. The new consultation looks at options to allow DC savers to transfer into a CDC scheme at retirement. This could provide a decumulation income option (in line with the forthcoming guided retirement framework).
Action: Consider whether CDC could be of interest to your scheme, in particular in light of upcoming guided retirement requirements.
New corporate identity verification and filing requirements now in force
Identity verification became compulsory for new directors and Persons with Significant Control (PSCs) of companies on November 18; existing directors and PSCs will need to verify their identity with their next annual confirmation statement. Verification will also be required for members of UK LLPs and directors of overseas companies that have a UK establishment.
There will also be changes to company register requirements and the information that needs to be provided to Companies House in relation to PSCs.
Action: Corporate trustees and other corporate structures must comply by the relevant deadlines. Voluntary verification ahead of mandatory deadlines is encouraged by Companies House.
Have your say
- The Information Commissioner's Office (ICO) is consulting on draft updated statutory guidance on investigations and enforcement under the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018. The consultation closes on January 23, 2026.
- The government is consulting on options for retirement CDC schemes (see more above). The consultation closes on December 4, 2025.
Watch this space
- The government intends to consult on trustee accreditation and governance later this year.
- 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.
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.
