Pensions Bulletin 2026/01

Welcome back to LCP’s Pensions Bulletin 

After a break over the festive period, LCP’s Pensions Bulletin returns, bringing you our weekly roundup of all things pensions regulatory and focussing mainly on the occupational pensions space. We kick off in this edition with much of our reporting being on matters that came out just after we had issued our final Bulletin in 2025. 

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Pension Schemes Bill debated in the Lords 

The Pension Schemes Bill had its first substantive outing in the House of Lords on 18 December 2025, when its Second Reading took place. 

Inevitably the speeches made were wide-ranging in nature, but if one theme came through it was that of significant concern about the Government taking asset allocation powers in relation to authorised master trusts and large group personal pension schemes with many peers objecting to such mandating in principle. However, a number of peers expressed worries with the very low level of investment by UK pension schemes in UK enterprises, with, for example, Lord Wood (Labour) talking about the need for the Government to obtain a “big stick” that it intends not to use if other measures it is taking create the climate for higher levels of domestic investment by UK pension schemes. 

Some peers such as Lord Davies (Labour), Baroness Bennett (Green Party) and Baroness Coffey (Conservatives) mentioned the recently published report of the House of Lords’ Delegated Powers and Regulatory Reform Committee which was scathing in nature saying that the Bill “is in large part a licence for Ministers to make sub-ordinate legislation” given the Bill’s skeletal nature comprising of 123 clauses and 119 delegated powers. The report went on to say that as such “the Bill cannot properly be comprehended or judged until many of its 119 delegated powers are in due course exercised by Ministers”. 

Committee stage is scheduled to start on 12 January 2026 and ahead of that many amendments have been tabled for consideration. Some of these are Government amendments in the name of Baroness Sherlock, with the 6 January 2026 amendment paper covering two topics in her name: 

• The establishment of a new public sector pension scheme into which the current AWE pension scheme is to be transferred whilst preserving existing rights of scheme members. This development, requiring nine new clauses, will take up a new Chapter 2A in Part 4 of the Bill. This follows on from earlier Government decisions to bring the scheme’s assets and liabilities into central government control. 
• An extension to the pre-1997 indexation on PPF compensation and FAS assistance provisions that were introduced to the Bill in the House of Commons (see Pensions Bulletin 2025/49). The new amendments are intended to provide that, where a scheme provided post 1988 GMPs, and there was an indexation requirement, but it did not apply in relation to pre-1997 service in respect of which the compensation or assistance is payable, indexation will apply to a percentage of the pre-1997 compensation or assistance. 

Pensions Regulator consults on an updated CDC Code of Practice 

On 19 December 2025 the Pensions Regulator launched a consultation on a new-look CDC Code of Practice that will take the existing Code that applies to single-employer CDC schemes and amend it so that it allows for multi-employer CDC schemes. The new Code will apply to authorisation and supervision of both types of CDC scheme. 

The Regulator says that it should be clear which aspects apply to both types of schemes and which apply only to either single-employer CDC or multi-employer CDC schemes. 

The Regulator says that while the introduction of multi-employer CDC schemes is a significant extension to the types of pension scheme available to employers, the Regulator’s role in authorising them does not represent a significantly new way of it operating. It goes on to say that many aspects of the proposed Code will be familiar as the approach to authorisation and supervision reflects those adopted for single-employer CDC schemes and Master Trusts in many areas. 

The Regulator also wishes to incorporate its Code for authorised CDC schemes into its General Code of Practice and with this in mind has presented the new CDC Code in the modular format of the General Code, with many of the modules relating to different aspects of the authorisation criteria. There are 39 modules in total, which after some introductory sections cover the following authorisation criteria:

• Systems and processes 
• Scheme proprietor 
• Fitness and propriety 
• Financial sustainability 
• Continuity strategy 
• Promotion and marketing 
• Sound scheme design 

The Code then goes on to consider some supervisory matters. 

The Regulator says that this Code includes new expectations, such as the company or person that financially supports the scheme, the way the scheme is promoted or marketed, and the fitness and propriety of key personnel associated with the scheme. 

Consultation closes on 13 February 2026 and the Regulator intends that its Code will come into force on the same day as the multi-employer regulations (see article below). 

Unconnected multi-employer CDC regulations issued in final form

Following their laying before Parliament in draft form in October 2025 (see Pensions Bulletin 2025/43), the extensive regulations relating to the expansion of CDC schemes to unconnected multiple employer schemes have been laid before Parliament in final form. 

The Occupational Pension Schemes (Collective Money Purchase Schemes) (Extension to Unconnected Multiple Employer Schemes and Miscellaneous Provisions) Regulations 2025 (SI 2025/1313) come into force on 31 July 2026. 

Government continues to freeze the auto-enrolment parameters

On 18 December 2025 the Government published the results of its review of the earnings trigger and qualifying earnings band to be used for auto-enrolment purposes for 2026/27. 

The earnings trigger above which individuals must be auto-enrolled will continue to remain frozen (as it has been since 2014/15) and the band of earnings on which minimum contributions are based will continue to be aligned to the Lower and Upper Earnings Limits for national insurance purposes. Therefore for 2026/27: 

• The automatic enrolment earnings trigger will be maintained at £10,000 pa 
• The lower limit of the qualifying earnings band will remain at £6,240 pa 
• The upper limit of the qualifying earnings band will remain at £50,270 pa 

The Government’s apparent rationale for this continued freeze is to maintain policy stability whilst the Pensions Commission considers a wide range of topics relating to pension adequacy, including auto-enrolment. 

The analysis states that freezing the earnings trigger will see private sector participation at 16.9 million in total. Although the equivalent figure this time last year was 15.7 million (see Pensions Bulletin 2025/03), this year’s report says that the 16.9 million figure is only an increase of 39,000 from last year, which on the face of it doesn’t add up!

Pension Schemes Newsletter 176 – update on tax adviser registration and pension matters 

HMRC’s Pension Schemes Newsletter 176 was published on 18 December 2025 and in common with many previous newsletters, covered a variety of topics, but it is that on tax adviser registration that is of most interest and so we turn to this first. 

Tax adviser registration 

An explanation is given of the mandatory tax adviser registration requirement being introduced by the Finance Bill (see Pensions Bulletin 2025/50). In relation to the impact of this requirement on pensions matters, HMRC states that the provision of information to clients or members (such as providing information about Annual Allowance charges or holding pre-retirement information sessions) is not caught by the requirement to register, as there is no interaction with HMRC about the clients’ tax affairs. 

HMRC also says that the exemption from the requirement to register for interactions with HMRC which are carried out in response to requirements under legislation, includes, for example: 

• pension scheme administrators 
• pensions practitioners 
• scheme managers of qualifying overseas pension schemes 
• qualifying recognised overseas pension schemes 
• responsible persons for employer-financed retirement benefit schemes 

HMRC confirms that those providing tax advice to clients which involve an interaction with HMRC and are not covered by the above exemption do need to register with HMRC. 

Other topics 

The other topics covered by the Newsletter are as follows: 

• Transfers to QROPS – Scheme administrators can now report a transfer to a qualifying recognised overseas pension scheme (QROPS) on the Managing Pension Schemes service and in early 2026 some enhancements will be made to this reporting. There is a link to materials for those who have yet to migrate their scheme to the Managing Pension Schemes service. 
• Protections and enhancements – Scheme administrators will be able to use the members protections and enhancements look up service on the Managing Pension Schemes service in early 2026. However, no date is given for what had previously been promised for delivery in late 2025. 
• Public service pensions remedy – an update is provided on the process for offsetting unauthorised payments as part of the public service pensions remedy, with guidance and a template spreadsheet being mentioned. 
• Residency status reports for relief at source schemes – Scheme administrators of relief at source pension schemes should have successfully submitted their annual return of information for 2024/25 tax year and if so should be told the residency tax status of scheme members in January 2026. 
• Pension scheme returns – there is a reminder that if called upon to submit a 2024/25 pension scheme return (which can only be submitted through the Managing Pension Schemes service), this must be done by 31 January 2026 if the scheme was migrated before 31 October 2025, and within three months of the notice to file for schemes migrated after 31 October 2025.  
• Event reporting – finally, there is a reminder that the deadline for submitting an event report for the 2024/25 tax year is 31 January 2026.