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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
- Pensions dashboards remain on track for the October 31, 2026 connection deadline. Schemes should prioritise data readiness; TPR signals robust enforcement for wilful or reckless failure to meet connection duties.
- TPR’s revised CDC code takes effect on July 31, 2026, supporting multi-employer CDC arrangements for unconnected employers.
- The PPF reports strong first-year progress under its 2025–28 strategy, with focus now shifting to implementation and delivery. It has also provided information on its approach to paying inflation increases on pre-97 benefits.
Dashboards: progress report and process evaluation
The Pensions Dashboards Programme (PDP) has published its latest progress update report, stating that dashboards connection remains on course for the deadline of October 31, 2026. As previously announced, the MoneyHelper Pensions Dashboard is expected to be available to the public in financial year 2027/28, with a further update on expected timings to be provided around the time of the October 31 connection deadline.
As part of the update, the Pensions Regulator (TPR) underlines the importance of schemes maintaining a focus on data quality, including value data. TPR also warns: “If schemes fail to meet the statutory deadline for connection, they can expect to hear from us. Where we see wilful or reckless non-compliance, we will take a robust enforcement approach.”
Separately, the PDP has published an evaluation of the dashboards connection process. The evaluation found that, overall, connection has been successfully delivered but aspects of the process have been technically more complex and resource-intensive than expected.
Read the progress update report and connection process evaluation.
Revised CDC code brought into force
Two statutory instruments have been made, bringing TPR’s revised code of practice for the authorisation and supervision of collective defined contribution (CDC) schemes into force with effect from July 31, 2026. The revised code reflects the move to allow CDC arrangements to be used for multiple, unconnected employers.
Read the order bringing the code into force and the order revoking the existing code.
PPF publications
The Pension Protection Fund (PPF) has published its annual report and accounts for 2025/26. The report includes analysis on the PPF’s key performance indicators and initiatives. It notes that it has made “excellent progress” during the first year of its 2025–28 strategy, which has focused on putting groundwork in place to allow it to progress against its strategic goals: acting in the interests of those it protects; helping shape change in the pensions industry; adapting and evolving; and building on its strong foundations. In the next financial year, the focus will shift to implementation and delivery of its objectives.
The PPF has also published information on its approach to providing inflation increases for compensation in relation to pension benefits built up before April 6, 1997, based on changes in the Pension Schemes Act 2026.
Read the annual report and accounts and the information on pre-97 indexation.
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