HL UK Pensions Law Digest 30 April 2026

Welcome to our latest update, in which we cover: 

The Pension Schemes Bill: receives Royal Assent

• The Pension Schemes Act 2026 has received Royal Assent and passes into law;

The Pensions Regulator: updated dashboards guidance

• The Pensions Regulator (TPR) has published updates to its guidance on dashboards, including new checklists;

The Pensions Regulator: market oversight report on dashboards

• The Pensions Regulator (TPR) has published a market oversight report on dashboards, together with an accompanying blog;

HMRC: Pension Schemes Newsletter 180

• HMRC has published its Pension Schemes Newsletter 180, which includes information on transitional arrangements for the increase in the normal minimum pension age (NMPA);

The Pensions Administration Standards Association: guidance on the operational challenge in relation to default retirement

• The Pensions Administration Standards Association (PASA) has published its guidance on the operational challenge facing pension scheme administrators in relation to default retirement.

The Pension Schemes Bill receives Royal Assent after mandation power compromise 

On 29 April, the Pension Schemes Bill received Royal Assent and became the Pension Schemes Act 2026.

The protracted Parliamentary deadlock had been centred on the proposed reserve power to mandate investment in private markets by certain defined contribution (DC) pension schemes.

In order to secure the Bill's passage, the government made further concessions, including strengthening the "savers' interest test". This will allow trustees to seek an exemption from any requirements imposed by the reserve power, if they reasonably conclude that compliance is likely not to be in the best interests of scheme members.

The focus will now shift to the implementation phase, with various consultations expected across a range of areas in the coming months. 

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The Pensions Regulator publishes updates to its dashboard guidance and two checklists

The Pensions Regulator (TPR) has updated its pension dashboards guidance and added two checklists.

The updates highlight good practice, the progress made by the Money and Pensions Service (MaPS) on the digital architecture, and provide clarity on areas TPR is often asked about.

The two checklists are designed to help schemes prepare for the dashboards regime: one for schemes which are still working to connect; and one for schemes which are already connected. They cover items set out in TPR's original checklist, but those items are now split into pre and post-connection steps for greater clarity, and now include enhanced detail.

The deadline for connection is 31 October 2026.

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The Pensions Regulator publishes a market oversight report into pension dashboards and an accompanying blog

On 23 April, the Pensions Regulator (TPR) published its market oversight report on pension dashboards.

TPR issued a questionnaire to schemes with more than 100,000 active and deferred members, with follow-up meetings where needed. TPR focused on:

• How schemes manage data quality day-to-day;
• Preparations for matching data (used to find dashboards users in their records); and
• Preparations for value data (used to return accurate and recent pension values to members through dashboards).

The results show that schemes have a range of data controls in place, with varying degrees of sophistication; and preparations for ensuring schemes have the right matching data are generally more advanced than for value data. The report notes that, for many schemes, further work is needed to embed data quality, monitoring and assurance into business-as-usual processes.

Best practice insights have been incorporated into the updated dashboards guidance.

In the accompanying blog, Lucy Stone (Pensions Dashboard – Business Lead) urges schemes to keep up the momentum, focus on value data and embrace the opportunities to learn from user testing. Noting that defined benefit (DB) and hybrid schemes are most likely to have out-of-date value data, TPR intends to contact a sample of those schemes next month, to understand their preparations.

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HMRC publishes its Pension Schemes Newsletter 180

On 23 April, HMRC published its Pension Schemes Newsletter 180. It contains articles on:

• Pension scheme return (PSR): dealing with the mechanics of submitting, viewing, searching and amending the PSR.
• Normal minimum pension age: early background, on a provisional basis, about the intended scope and effect of the transitional regulations that will support the increase to normal minimum pension age from age 55 to age 57 on 6 April 2028.
  • The Newsletter provides examples of how the transitional regulations will apply in various scenarios, both in relation to pension payments and in relation to the payment of pension commencement lump sums.
  • The transitional regulations will apply to all registered UK pension schemes, and to members who have reached age 55 on or before 5 April 2028. The aim of the transitional regulations will be to ensure that members who have already become entitled to their pension benefits can continue to receive them seamlessly.
• Lifetime allowance protection and enhancements: a reminder that the protection "look-up" service to help scheme administrators verify member protections, is now available; and that the unauthenticated look-up service is closed.
• Digitisation of relief at source: a reminder that new deconsolidated relief at source references must be used from May 2026 in respect of claims relating to (and after) April 2026.
• Relief at source returns: a reminder of the 5 July 2026 submission deadline, together with some information on the practicalities.
• Pension schemes migration to the "managing pension schemes service": a reminder that failure by schemes to migrate to the new service will prevent them from fulfilling their reporting obligations.
• Pension flexibility statistics: information on the number of tax repayment claim forms processed for pension flexibility payments.
• Registration statistics: HMRC received in total 2,421 applications to register new pension schemes in the year 2025-26. 54% of these have been registered; 33% of applications were refused; no decision has yet been made on the remainder.

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The Pensions Administration Standards Association publishes guidance on the operational challenge in relation to default retirement

On 23 April, the Pensions Administration Standards Association (PASA) published guidance on the operational challenge facing administrators as default retirement solutions are introduced.

The paper, Default Retirement: The Operational Challenge Facing Administrators, sets out how upcoming guided retirement duties will fundamentally reshape defined contribution (DC) administration.

The guidance outlines the practical steps which can be taken to prepare; and examines potential delivery models, key risks and potential mitigations. It highlights the scale of change required across systems, processes and governance frameworks.

With master trusts expected to implement default retirement solutions from 2027 (and single employer schemes and group personal pensions from 2028), the guidance notes that administrators have a limited window to design, build and deliver new default retirement processes.

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Authored by Susanne Wilkins.