HL UK Pensions Law Digest 19 June 2026

Welcome to our latest update, in which we cover:

Auto-enrolment: alternative quality requirements for defined benefit (DB), hybrid and collective defined contribution (CDC) schemes

• A call for evidence on how the alternative quality tests as part of the DWP’s triennial review;

Flexible apportionment arrangements (FAAs): Ministerial Statement

• The government intends to review the safeguards surrounding FAAs;

Pensions Dashboards: Pensions Administration Standards Association (PASA) guidance

• Guidance from PASA on ongoing compliance monitoring.

Auto-enrolment: defined benefit, hybrid and collective defined contribution schemes

The DWP has issued a call for evidence on the alternative quality requirements for defined benefit (DB), hybrid and collective defined contribution (CDC) schemes used for auto-enrolment.

As a reminder, regulations set out alternative tests which employers may use to demonstrate that the benefits provided are sufficient for auto-enrolment. The DWP must review the regulations at least every three years and is seeking views and information about use of the alternative tests since the previous review in 2023.

The call for evidence closes on 27 July 2026.

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Flexible apportionment arrangements: Ministerial Statement

The Pensions Minister (Torsten Bell) has made a written statement in the House of Commons on the use of flexible apportionment arrangements (FAAs) in relation to defined benefit (DB) schemes.

The FAA legislation was introduced in 2012 and was intended to ensure that corporate activity did not trigger s75 debts, where there was an appropriate sponsor which could assume responsibility for the withdrawing employer’s liabilities.

The Minister notes that in December 2025, an asset manager took over responsibility for the assets and liabilities of another employer’s DB scheme (for more information please see the asset manager’s press release). He comments that the transaction relied on a “novel use” of the FAA legislation which was not anticipated when the FAA provisions were brought in.

The government intends to review the legislation governing FAAs to ensure that regulatory standards and safeguards remain appropriate, in light of innovation in the pension industry and the commercial operation of DB schemes.

The DWP intends to consult in due course on whether and how the current FAA regulations could be tightened. We are interested to see the consultation and DWP's concerns. The Pension Regulator already has strong powers (including the option to prosecute criminal offences) to deter activity that is damaging to DB pension schemes.

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Pensions Dashboards: PASA guidance to support ongoing compliance

The Pensions Administration Standards Association (PASA) has issued new guidance to help schemes and administrators to monitor ongoing compliance with pensions dashboards requirements following initial connection to the dashboards ecosystem.

PASA has also issued a Dashboards Toolkit covering the treatment of survivor benefits.

The ongoing compliance guidance focuses on three main areas:

• Matching: savers to pensions following receipt of Find Requests;
• Providing pension information: in response to View Requests; and
• Connection performance: maintaining connectivity and ensuring compliance.

For each of these areas, the guidance sets out the fundamental legislative requirements; expectations of the relevant regulators (the Pensions Regulator (TPR) and the Financial Conduct Authority (FCA)); and specific compliance indicators which should be monitored.

The guidance also contains a section on contact with savers, including complaints, queries and member feedback.

A further section sets out the internal reporting likely to be necessary for monitoring compliance and references guidance on reporting breaches of the law.

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Authored by Jill Clucas.