Here is our weekly summary of key legal and regulatory developments relevant to occupational pension schemes that you might have missed, with links for further information.
- An updated version of the Pension Schemes Bill has been published, which incorporates all the amendments made to the bill by the public bill committee. A date has not yet been set for the report stage and third reading of the bill in the House of Commons. The House of Commons is now in recess until 2:30 p.m. on 13 October 2025.
- The finance bill sub-committee has launched a call for evidence in relation to the draft legislation that will impose inheritance tax on unused pension funds and certain death benefits. There is a short window for responding – the call for evidence closes at 5 p.m. on 7 October 2025.
- Pensions UK has published a feasibility review of small pots consolidation. This review was commissioned by the Department for Work and Pensions (DWP). The report concludes that a central clearing house would be “costly and complex” to build. A federated design (where providers can communicate directly through existing open standards and messaging frameworks) would be preferable. The scale of development would be similar to dashboards for schemes with eligible Defined Contribution (DC) pots in the scope of the regulations. We expect a stage two review before the government engages with industry, and starts to progress regulations ahead of the planned 2030 implementation.
- We have mentioned in previous updates that from 18 November directors of a corporate trustee will be required to verify their identity with Companies House as part of the trustee company’s annual confirmation statement submission, but that this verification process can be undertaken earlier on a voluntary basis. Several clients have asked about the position when one of the directors of a corporate trustee is itself a company. Identity verification for corporate directors is not yet possible. A recent Companies House announcement states that it will introduce identity verification at a later date (still to be determined) for corporate directors.
- The Pensions Regulator (TPR) has published a market oversight report on how well pension schemes are prepared for liability driven investment (LDI) risk. This follows on from guidance that TPR published in April 2023. The oversight report includes the steps that pension schemes, and the investment industry, have made to improve “operational resilience”. The report also sets out TPR’s expectations of trustees in relation to stress testing, understanding liquidity profile, pre-agreed asset sale plans, governance and having signatories available to sign instructions during times of market stress.
- TPR has issued an enforcement strategy consultation, which closes on 11 November 2025. The “focused, agile and outcomes-driven model” is aligned with TPR’s shift towards a more prudential style of regulation.
- The Pensions Administration Standards Association (PASA) has issued a dashboards toolkit on the use of warning codes and unavailable codes to help with the consistency of information that is returned to dashboards users.
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If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.