Pensions Bulletin 2025/31

PPF levy put on hold

The PPF has announced that it is still considering not charging a levy for conventional schemes for the 2025/26 levy year. This follows changes it made in the levy rules in January (see Pensions Bulletin 2025/05), which newly included a provision to allow the PPF to invoice a zero levy if legislation is brought forward, and sufficiently progressed to enable the PPF to bring back levy charges in the future if needed.

The Pension Schemes Bill, published in June, includes such provisions on the PPF levy. The PPF will continue to monitor progress as the Bill works its way through Parliament, before making a final decision. The PPF expects to provide a further update on the levy this Autumn, and in the meantime will publish mean D&B scores as usual for employers linked to PPF-eligible schemes.

TPR urges trustees to consider systemic risks 

Mark Hill, the Climate and Sustainability Lead at the Pensions Regulator, has written a blog to remind trustees that understanding and managing systemic risks, where they are financially material, are part of their fiduciary responsibilities.  

Mr Hill says that trustees will need strong investment governance in complex areas such as environmental, social and governance, and private markets, and should ensure that decisions are long-term, well-evidenced, and subject to appropriate challenge. The Regulator is raising its expectations around investment governance, with a sharper focus on systemic risks.  

The blog also links to resources available to help trustees address systemic risks, including those produced by the Regulator as well as tools published by the Taskforce on Nature-related Financial Disclosures. It lists several questions that trustees should ask themselves as they navigate through this topic.  

Finally, following the recent publication of the Government’s consultation on climate-related transition plans (see Pensions Bulletin 2025/26), the Regulator is convening an industry working group to develop thinking around a practical approach to transition planning for occupational schemes, and has invited trustees to submit written evidence towards this by 1 September.  

HMRC’s Pension Schemes Newsletter 171  

HMRC’s latest Pension Schemes Newsletter leads with a summary of the inheritance tax material published on Legislation Day, 21 July 2025 (see Pensions Bulletin 2025/29 for more detail). The article provides no new information or clarification of the policy proposals or draft legislation, though it does remind us that the Government intends to publish further draft legislation in due course on the changes that will be required to the information sharing regulations to support these proposals.  

Beyond that the Newsletter carries numerous articles, mainly of interest to those carrying out day to day tax administration of a registered pension scheme. It includes articles on the new authenticated look up service for checking whether members have lifetime allowance protections or enhancements which is due to launch later this year, completing relief at source annual returns and using the managing pension schemes service to submit pension scheme returns. It also contains the latest quarterly pension flexibility and annual QROPS statistics, which show that £872m left the country in 2024/25 (and about £2bn over the last two years) – an increase on previous years.  

PASA’s new guide to data security  

The Pensions Administration Standards Association has published new guidance, “Securing Tomorrow: Essential Steps for Trustees and Pension Providers to Protect Member Data”. In a few pages, the guidance sets out a summary of the key security risks, and then provides a concise and useful list of steps that trustees can take to improve data security and governance. At the end it provides links to the Pensions Regulator’s guidance and the National Cyber Security Centre’s material on the same topic.  

The Pensions Ombudsman looks forward to the next three years

Two weeks after announcing a successful 2024/25 (see Pensions Bulletin 2025/29), the Pensions Ombudsman published its Corporate Strategy for 2025 – 2028 and its Corporate Plan for 2025/2026. The new strategy focuses on two goals:

• Providing an efficient, accessible and quality service – this builds on the success over 2024/25 and looks for additional efficiencies, which includes using AI for administrative tasks, although the Ombudsman stresses that AI will not be used for decision making. There is also a focus on enhancing people’s experience, and to review and improve customer journey.
• Being an authoritative voice for improvement in the pensions industry – this includes improving schemes’ internal dispute processes, providing guidance and information to the pensions industry to prevent issues becoming complaints, and helping pension scheme members understand how to manage their issues effectively and where to go for help.

Even with the planned improvements in dispute processes before issues becomes complaints, the Ombudsman is still forecasting a 12% year-on-year increase in new pension complaints over the next three years.

The Ombudsman suggests that, as well as the expected increase because more people will reach retirement age combined with a stretched pensions industry, much of the caseload increase could come from developments in the pensions landscape. These include the new Pensions Schemes Bill bringing in small pot consolidation and default decumulation options with associated teething problems; the Pensions Dashboard may raise pensions awareness, bringing any issues to the fore; and the consolidation of smaller schemes is likely to identify issues that can give rise to complaints.