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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.
HMRC: details on IHT changes
HMRC has published a technical note giving more details on the application of inheritance tax (IHT) to pensions and a consultation on draft regulations for the exchange of information between PRs and pension schemes is now under way. Further guidance and tools will be provided by spring 2027. Our briefing provides an overview of the changes.
Action: Start preparing for significant changes needed to comply with the new IHT requirements.
Pension Schemes Act receives Royal Assent
The Pension Schemes Act 2026 has received Royal Assent, laying the ground work for a range of significant changes to the UK pensions landscape.
The Act includes legislation for a new DC Value for Money framework and for the consolidation of small, dormant DC pots; requirements for master trust and GPP main scale default funds; the framework for guided retirement solutions; and more. Most of the changes require further detail to be set out in regulations.
Action: Most areas require a watching brief for now, pending further regulations.
New data complaints processes
Most of the provisions of the Data (Use and Access) Act 2025 (DUAA) have now been brought into force. These changes include a requirement for data controllers to have a process in place to deal with data protection-related complaints from June 19, 2026. This includes a complaint form that can be completed electronically; acknowledging receipt of a complaint within 30 days; responding to the complaint without undue delay; and communicating the new right to complain in privacy notices and SAR responses.
The ICO has published guidance to assist data controllers.
Action: Adopt processes to address complaints in line with these requirements; review privacy notices and other communications.
TPR warning on impersonation fraud
TPR has issued a scam alert setting out steps that schemes should take following a significant increase in impersonation fraud targeting pension savers.
Action: Review the alert and implement the actions recommended by TPR.
TPR publishes AI plan
TPR has published an AI plan, outlining expectations for the adoption and governance of AI in workplace pension arrangements. TPR expects trustees and administrators to establish robust governance and accountability for their own, and providers’, use of AI systems and technologies; to understand how AI models use and process data, and to seek advice when required. More detailed guidance is to follow.
Action: Read the AI plan and consider the implications for your scheme.
TPR: dashboards updates
TPR has updated its dashboards guidance to answer common questions and highlight best practice and has provided two checklists to help schemes prepare for dashboards duties.
TPR has also updated its guidance on reporting breaches of the law to include two dashboard-related examples of “green breaches“.
It has been confirmed that the “go live” date for dashboards is likely to be in financial year 2027/28.
Action: Consider the guidance as part of dashboards compliance projects.
Watch this space
The government is developing guidance for trustees on their fiduciary duties, aimed at supporting trustees in considering factors including systemic risks (such as climate change) and members’ standards of living.
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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