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Welcome to your weekly update from the A&O Shearman Pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions.
Summary
- TPR updates dashboards guidance with clarifications, checklists and best practice.
- HMRC’s latest newsletter gives an insight into transitional arrangements for normal minimum pension age increase in 2028.
- The government has announced it will be updating its Pensions Roadmap.
- PASA publishes new guidance on operational challenges in preparing for guided retirement duties for occupational DC schemes.
TPR: updated dashboards guidance
TPR has updated its dashboards guidance to answer common questions and highlight best practice. This is accompanied by two checklists to help schemes prepare for dashboards: one for schemes that are still working to connect, and one for schemes that are already connected. The updates reflect the latest guidance from the Money and Pensions Service (MaPS), progress with the central digital architecture, clarification of policy intent from DWP, feedback from the industry, and ongoing developments and learnings.
TPR has also published a report on findings from its engagement with large schemes on data preparations. TPR found that levels of data readiness are uneven; preparations for data matching were generally more advanced than for value data; and for many schemes, further work is needed to embed data quality, monitoring and assurance into business-as-usual processes. The report includes specific actions all schemes should take and highlights best practice. TPR will shortly be looking at the value data preparations of DB and hybrid schemes—it will reach out to a sample of these schemes next month. The insights into how dashboards are working in practice from MaPS and industry will be used to inform the discussions on the timing of launch of the MoneyHelper dashboard.
Read TPR’s updated guidance, checklists, report and blog post.
HMRC: latest pension schemes newsletter—NMPA transition update
HMRC has published its latest Pension Schemes Newsletter (no. 180). The newsletter includes discussion of transitional arrangements for the increase of normal minimum pension age (NMPA) from 55 to 57 on April 6, 2028. Work is ongoing to develop the regulations which will govern those transitional arrangements but the newsletter gives some early background about their intended scope and effect, on a provisional basis, subject to change as the regulations are finalised. It states that “the aim of the transitional regulations is to ensure that members who have already become entitled to their pension benefits can continue to do so seamlessly”.
The newsletter sets out examples of how transitional provisions may apply in a range of scenarios where entitlement to/payment of benefits spans across April 6, 2028 and the recipient has reached age 55 but not 57.
The newsletter also includes sections on: filing, viewing and amending scheme returns; the lifetime allowance protection look up service; submitting claims and annual returns for relief at source; and action needed to migrate to the Managing pension schemes service.
Upcoming updates to government’s pensions roadmap
The Pensions Administration Standards Association (PASA) has published new guidance on operational challenges facing administrators as guided retirement duties for occupational DC schemes are introduced (expected to take effect from 2027). The guidance states that “administrators will need to make major changes. Many current processes will no longer be fit for purpose. Both frontline services and back-office processes will need to evolve alongside system design.” It sets out a range of practical considerations for implementation of the new model; discussion of risks and mitigations; possible delivery models; and communication issues.
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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