Pensions Bulletin 2025/47

This Pensions Bulletin covers our normal weekly round-up of regulatory and other developments. It has been issued ahead of the Chancellor’s 26 November 2025 Budget speech. A separate Budget Bulletin is being issued looking at Budget-related announcements which are of potential relevance to pension schemes and their members.

Pension Schemes Bill to wrap up in the Commons

The Pension Schemes Bill is to move to Report stage in the House of Commons on 3 December 2025, following which it will have its Third Reading before being sent to the House of Lords, almost certainly before the Christmas break. Ahead of Report stage a number of amendments are appearing and in this article we report on those set out in the 26 November 2025 amendment paper, although as none are from the Government, these amendments are unlikely to proceed further.

Six amendments (NC6, NC7, NC18, NC22, NC23, NC24) relate to the pre-1997 indexation issue on which the Government will need to make a final decision shortly. But if it does decide to proceed with some form of pre-1997 indexation (on PPF, FAS and potentially DB scheme benefits in certain circumstances) it will almost certainly bring forward its own legislation.

Many of the other amendments are on all kinds of disparate topics not directly related to the issues that the Government wishes to address in this Bill. These include calls for reviews into:

• the pension losses incurred by former employees of AEA Technology;
• investment in defence companies within Local Government Pension Schemes and how that impacts and aligns with Government international obligations;
• the efficacy of investment in terms of delivering social good and the benefits of directing more investment towards social housing and green technology; and
• the impact and fairness of provisions within police pension schemes that result in the forfeiture, reduction, or suspension of survivor pensions.

There is also an amendment (NC17) that adds certain matters that can be taken into account when trustees take investment decisions.

PASA publishes new data guidance

The Pensions Administration Standards Association has published two new pieces of guidance that are intended to support schemes in responding to the Pensions Regulator’s member data quality guidance that has recently been updated (see Pensions Bulletin 2025/46). The PASA documents are:

• The Six Data Quality Dimensions for Pension Scheme Member Data – which explores the Regulator’s six core data dimensions – accuracy, completeness, consistency, timeliness, uniqueness and validity, and provides detail on how schemes can assess and improve the quality of member data across these areas.
• Data Improvement Plan (DIP) Template – which gives schemes a framework for planning, documenting and delivering data improvement activity.

There is also a panel discussion on the Regulator’s updated guidance.

PASA issues first in guidance series on delivering effective digital transformation

The Pensions Administration Standards Association has published new guidance which aims to provide practical direction for schemes embarking on, or progressing through, digital transformation of their pensions administration processes. The guidance, which is the first in a new three-part guidance series from PASA, outlines how schemes can establish the right frameworks, technologies and cultural mindset to ensure successful and sustainable digital change.

This part one is intended to lay the groundwork for effective transformation by helping schemes assess their current technological maturity, identify opportunities and plan their next steps. Part two, due in January 2026, will focus on actionable strategies and planning frameworks for delivering digital transformation, regardless of scheme size or digital maturity. 

More blogs from the Pensions Dashboards Programme

The Pensions Dashboards Programme has published two blogs recently.

The first, published on 18 November 2025, looks at who will be able to use pensions dashboards explaining that there are some practical reasons that will limit some people’s ability to access dashboards, or change their experience of using them.

The second, published on 21 November 2025, addresses the benefits for schemes and their members of investing in data quality, not only for the success of pensions dashboards, but wider, with material from the Pensions Regulator setting out its view as to why data readiness can help create a wealth of opportunities for members, pension providers and schemes, and the wider industry.

Revaluation Order published

The Occupational Pensions (Revaluation) Order 2025 (SI 2025/1211) has been laid before Parliament setting out the final salary method revaluation percentages to apply to that part of a deferred pension in excess of any GMP for each deferred pensioner reaching their scheme’s normal pension age in 2026. These percentages are based on the lesser of (a) the percentage increase in inflation (on a CPI basis since September 2011), subject to a floor of 0%, and (b) either 2.5% or 5.0% pa, each measured over the whole deferment period before comparison.

This year the Order’s one year revaluation factor is equivalent to a 2.5% and 3.8% increase for the 2.5% and 5.0% capped rates respectively. These one-year factors will in turn drive the 2.5% and 5.0% Limited Price Indexation pension increases that DB occupational pension schemes are required to deliver as a minimum for pensions attributable to pensionable service from 5 April 2005 and between 6 April 1997 and 5 April 2005 respectively.