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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. Regulations on the exchange of information between personal representatives and pension schemes have been finalised. 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.
TPR: dashboards updates
The Pensions Regulator (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. The Pensions Dashboards Programme (PDP) has confirmed a revised timetable for new daily dashboards reporting requirements.
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 and ensure preparations are being made for daily reporting.
Pension Schemes Act—Royal Assent plus details of proposals and timing
The Pension Schemes Act 2026 has received Royal Assent, laying the groundwork for a range of significant changes to the UK pensions landscape.
A revised roadmap setting out timelines for the implementation of the changes has been published, alongside various related documents:
- A consultation on the Value for Money framework (see below)
- A DC scale requirements discussion paper.
- Principles for guided retirement
TPR has published a new web page summarising the changes introduced by the Act and how to prepare.
Action: Most areas require a watching brief for now, pending further regulations.
New guide for DC wake-up packs
The Money and Pensions Service (MaPS) has published a redesigned guide to be included in ‘wake-up’ packs for DC members.
Action: Include the new guide in wake-up packs.
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.
Action: Read the AI plan and consider the implications for your scheme. More detailed guidance is to follow.
Company accounts reforms
The government has announced that accounts reforms will come into effect from April 2028. These include: requiring filing of profit and loss accounts; requiring use of commercial software; removing the option of abridged accounts; a strengthened eligibility statement for companies claiming an audit exemption; and changed filing requirements.
Action: Corporate trustees should review whether they are impacted by the changes.
Have your say
- A consultation on draft Value for Money regulations has been launched, including phased implementation and more lead-in time. The consultation closes on September 7, 2026.
- A consultation on changes to the General Levy has been launched, closing at midday on September 8, 2026.
Watch this space
- The government is developing guidance for trustees on their fiduciary duties.
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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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