HL UK Pensions Law Digest 24 April 2026

Welcome to our latest update, in which we cover: 

Pension Schemes Bill: race to the finish

• Concessions from the government to push the Bill over the line but agreement has yet to be reached on the reserve investment power;

Pensions Administration Standards Association: guidance on contingent spouse pension data

• The Pensions Administration Standards Association (PASA) has published its guidance on contingent spouse pension data and calculation approaches;

Pensions Regulator: summary of the Pension Scams Action Group’s Fighting Pension Fraud webinar

• The Pensions Regulator (TPR) has issued a press release, summarising issues discussed at the Pension Scams Action Group’s Fighting Pension Fraud webinar;

Pensions Regulator: new Chair appointed

• Emma Douglas has been appointed as the new Chair of the Pensions Regulator (TPR), with effect from 1 July 2026.

Pension Schemes Bill: race to the finish 

The Pension Schemes Bill is continuing the process of “Ping Pong” and is passing between the House of Commons and the House of Lords to iron out remaining disagreements before the Bill can be passed. Time pressure is on, as Parliament must be prorogued no later than 5 May 2026, which will bring the current session of Parliament to an end. Bills not passed by this time will fall away, unless a carry-over motion has been passed.

The remaining areas being considered are as follows.

Reserve power to mandate investment for Master Trusts and group personal pensions (GPPs)

The Lords have continued to reject the asset allocation condition, which would give the government a reserve power to make regulations requiring Master Trusts and GPPs subject to the defined contribution (DC) scale requirements to invest at least a prescribed percentage of their assets in particular asset classes (“qualifying assets”).

In an attempt to reach agreement, the government had proposed additional restrictions on the power, so that regulations could not compel schemes to invest in a single asset class and could only require:

• Up to 10% (by value) of the assets held in default funds in the scheme as a whole to be qualifying assets; or
• Up to 5% (by value) of the assets so held to be of a “UK-specific description” (as defined).

A qualifying asset would be of a “UK-specific description” if, broadly, it was located in the UK or met any other condition linked to economic activity in the UK.

On 22 April 2026, in a further attempt at consensus, the government proposed further amendments which would:

• Provide that the power to set a minimum percentage for investment in qualifying assets could only be used once;
• Bring forward the sunset provision (when the power to make regulations will fall away if not yet used) from the end of 2035 to the end of 2032; and
• Repeal the entire asset allocation mandation regime from the end of 2035.

The Lords rejected these proposals and the government’s further concessions and insisted on removing the asset allocation reserve power again.

For more details of the scale and asset allocation requirements please see our Digest of 2 June 2025.

Scale requirement for Master Trusts and GPPs: impact of consolidation

• The Lords has backed down on its proposed amendment to add an exemption from the scale requirement if there was no reasonable evidence that consolidation would be likely to improve member outcomes.
• Instead, the Lords accepted a new government amendment which will require the Secretary of State to publish a report about the effects of consolidation on innovation in the design and operation of relevant Master Trusts and GPPs. The report must be published within 12 months of the Bill receiving Royal Assent.

Scale requirement: factors to consider when making regulations

• The Lords had inserted a requirement for the Secretary of State, Financial Conduct Authority (FCA) and the Pensions Regulator (TPR) to have regard to the benefits of competition among pension providers, when making regulations concerning the scale requirement.
• The Lords has accepted the removal of its amendment and has agreed an alternative, wider provision proposed by the government, which will require regard to be given to various matters when making regulations, including:
  • Innovation in the design and operation of Master Trusts and GPPs;
  • Competition among pension providers;
  • Improving member outcomes;
  • Achieving an appropriate scale; and
  • Effective governance.

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The Pensions Administration Standards Association publishes guidance on contingent spouse pension data and calculation approaches

On 16 April, the Pensions Administration Standards Association (PASA) published new guidance from its Data Working Group, focusing on contingent spouse pension (CSP) construction.

A CSP is a pension payable under scheme rules to a surviving spouse, civil partner or other qualifying dependant on the death of a defined benefit (DB) scheme member - whether in active service, deferment, or retirement. The guidance focuses on pensioner members, due to the increased complexity of CSP calculations for this category.

The guidance provides schemes with a practical framework for assessing, calculating and maintaining CSP values, with a primary focus on data quality. It explores a range of calculation approaches and highlights the data requirements, risks and governance considerations for schemes.

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The Pensions Regulator reports on the Pensions Scams Action Group's Fighting Pensions Fraud webinar

On 16 April, the Pensions Regulator (TPR) issued a press release summarising the key issues to emerge from the Pension Scam Action Group's (PSAG's) webinar: Fighting Pension Fraud.

The PSAG is a multi-agency taskforce led by TPR, with the aim of tackling pensions fraud.

Points to note from the webinar include:

• The Fraud Minister, Lord Hanson, urged trustees to use “every touchpoint” with members to reinforce scam warning messaging;
• Attendees (over 550 trustees, advisers and administrators) were urged to:
  • Commit to TPR’s industry Pledge to Combat Pension Scams campaign;
  • Get up to date on the latest scam warnings;
  • Educate their members on the risks and how they can keep themselves safe; and
  • Tell Report Fraud about any suspicions.
• The webinar considered TPR's work, in collaboration with others, to identify and take down potential scam websites; and
• It also included an overview of Report Fraud, the new cyber-crime and fraud reporting service.

The webinar took place on 18 March 2026. A full recording is available here.

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The Department for Work and Pensions announces Emma Douglas as the new Chair of the Pensions Regulator

On 21 April, the Department for Work and Pensions (DWP) announced that Emma Douglas has been appointed as the new Chair of the Pensions Regulator (TPR).

Ms Douglas has more than 25 years of experience in the investment management and pensions industry, including as Wealth Policy Director at AVIVA and as Chair of Pensions UK.

Ms Douglas's five-year term begins on 1 July 2026, when current Interim Chair, Kirstin Baker, steps down.

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Authored by Jill Clucas and Susanne Wilkins.