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Welcome to your weekly update from the A&OShearman Pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions.
Summary
FRC issues non-mandatory guidance on retrospective actuarial confirmations post-Virgin Media, promoting a proportionate, evidence-based approach; TPR guidance expected in spring.
MaPS consults on updated dashboards reporting standards, proposing daily automated reporting.
Plus: PASA provides practical guidance for buy-ins and superfund transfers; and HMRC's latest newsletter.
Actuarial guidance onVirgin Mediaconfirmations
The Financial Reporting Council (FRC) has published guidance for actuaries on giving confirmations to validate historic alterations after the Virgin Media decision. The guidance is not mandatory and may change as the Pension Schemes Bill progresses through Parliament. TPR will publish guidance to support trustees on this issue "in spring".
As a reminder, the Pension Schemes Bill includes a remedy to help deal with issues created by the Virgin Media decision. If a scheme has a historic alteration which does not have a necessary actuarial confirmation, trustees can request a retrospective confirmation to validate it. The actuary must confirm that, in their opinion, it is reasonable to conclude that the alteration would not have prevented the scheme from continuing to satisfy the statutory standard. The actuary may act on the basis of the information available, as long as they consider it sufficient.
What are the key messages from the FRC guidance?
The FRC's guidance promotes a proportionate approach by actuaries in assessing whether they can give a confirmation. It stresses that the test does not require certainty; the actuary needs to reach a "reasoned and justifiable conclusion, taking into account all the relevant facts and circumstances identified after taking a proportionate approach to the gathering of data".
What does the FRC guidance say about data gathering?
Much of the guidance focuses on how much data actuaries need. The FRC encourages actuaries to use information that can be obtained without a disproportionate amount of time and effort. It includes helpful examples to illustrate how to approach different scenarios. The guidance suggests that actuaries should first consider whether an understanding of the rule alteration alone is sufficient to determine that it would not have prevented the pension scheme from continuing to meet the reference scheme test. Where more information is needed, the scheme actuary is encouraged to look for indirect evidence, such as legal advice, trustees' meeting minutes, or member communications. The guidance suggests that few cases should require individual member data.
Dashboards: Consultation on updated reporting standards
The Money and Pensions Service (MaPS) is consulting on dashboards reporting standards (which deal with generating and recording operational information and reporting it to MaPS). The consultation closes on March 25, 2026. The changes being proposed are largely aimed at requiring daily, automated reporting of data. Currently this data is only required to be provided to MaPS on request. The proposals relate to the mechanisms around reporting, not the data requirements for what must be recorded and reported. The updates also look to clarify an ambiguity in the current standards on when calculation times must be reported. MaPS is proposing to implement the updated standards by November 30, 2026. In advance of this, schemes and providers will need to have built compliant reporting systems (which MaPS estimates will take up to four months) and completed several rounds of testing.
PASA guidance on buy-in and superfund transitions
The Pensions Administration Standards Association (PASA) has published guidance for trustees, administrators and advisers on managing the operational and administrative aspects of buy-in transactions and superfund transfers. The guide gives practical tips on priority areas: aligning administration; reviewing and codifying longstanding practices and informal discretions; data integrity, both before and after the transition; transparent member communication; particular issues for deferred members; effective risk management; and resourcing and budgets.
HMRC: Latest pension schemes newsletter
HMRC has published its latest pension schemes newsletter (no. 177). It includes a reminder that from April 6, 2026, all scheme administrators of registered pension schemes will be required to be UK resident; a request for volunteers to test a new digital service for reporting the details of an inheritance tax payment notice, in advance of the upcoming inheritance tax and pensions reforms; and guidance on residency status reports for relief at source.
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