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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
- The DWP is consulting on whether automatic enrolment alternative quality tests remain fit for purpose.
- MaPS has published a redesigned DC guide for inclusion in wake-up packs.
- PASA’s new dashboards guidance provides a practical compliance monitoring framework alongside clarifications on survivor benefit flags.
- The government has signalled a review of flexible apportionment arrangements.
- New regulations expand UK trust registration requirements to certain non-UK trusts.
Call for evidence: automatic enrolment alternative quality tests
The DWP has published a call for evidence on the alternative quality requirements used by DB, hybrid and CDC schemes to satisfy automatic enrolment duties. It is required to carry out a review of these arrangements at least every three years.
The call for evidence asks whether the tests still deliver simplification and flexibility; who carries out and signs off certification; what cost, time and governance processes are involved; and whether any operational issues or future concerns have arisen. For CDC schemes, DWP is also seeking views on whether the alternative quality requirements remain appropriate for single and connected employer schemes, and whether they are appropriate for new unconnected multi-employer CDC schemes. Responses should be submitted by July 27, 2026.
MAPS publishes replacement for DC “Your pension: your choices” guide
The Money and Pensions Service (MaPS) has published a redesigned guide to replace its “Your pension: your choices” guide. The guide is relevant to DC pensions and must be included in “wake-up” packs sent to members approaching retirement age. The new guide, “How to take your pension” has been reduced in length and rewritten to provide clearer, step-by-step directions to help members understand their retirement options and signpost further sources of help and support.
PASA: new dashboards guidance
The Pensions Administration Standards Association (PASA) has published guidance on the ongoing monitoring of compliance with pensions dashboards requirements and on survivor benefits.
The compliance monitoring guidance focuses on practical monitoring across three key areas: matching, pension information provision and connection performance. For each area, the guidance sets out the fundamental requirements, regulators’ expectations and compliance indicators schemes should monitor. It identifies the primary source of relevant information and provides guidance on specific areas of potential difficulty. It also covers the requirement to monitor saver contact.
The separate survivor benefits guidance addresses some uncertainties regarding the application of survivor benefit flags.
Read the compliance monitoring guidance and survivor benefits guidance.
Government to review Flexible Apportionment Arrangements
Pensions Minister Torsten Bell has announced that the government intends to review the legislation around Flexible Apportionment Arrangements (FAAs) “in due course”. FAAs were introduced in 2012 and allow a replacement sponsor to take on liabilities of an employer that stops participating in a DB scheme. The government says it wants to ensure the regulatory standards and safeguards evolve to keep pace with developments in the market.
Trust registration requirements for non-UK trusts
Regulations have been made and laid before Parliament which include changes to the trust registration requirements. Trusts holding sums or assets of a UK registered pension scheme are excluded from the relevant requirements, so this will not affect most trustees, but clients should consider whether they have any trust structures which could be impacted.
The changes expand the scope of the requirements to cover non-UK trusts which acquired an interest in land in the UK before October 6, 2020 and continue to hold that interest. There are also changes which may, in some circumstances, affect non-UK trusts with no UK-resident trustees which acquire an interest in UK land.
Read the Money Laundering and Terrorist Financing (Amendment) Regulations 2026.
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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