Pensions Bulletin 2026/16
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This edition: Pension Schemes Bill – ping-pong!, PASA guidance on contingent spouse pension data and calculation approaches, Fraud Minister’s plea to trustees and administrators and more.

Pension Schemes Bill – ping-pong!
On 20 April 2026, in the second stage of a ping-pong match between the Lords and the Commons in relation to the Pension Schemes Bill, the House of Lords stood its ground in four areas in which non-Government amendments it had made at Report stage had been voted down in the Commons (see Pensions Bulletin 2026/15).
The four areas, made clear in the Lords’ conclusions, were as follows:
- Mandation – the House of Lords insisted that the Commons consider, once more, the amendments the Lords made, stripping out all of the Government’s asset allocation mandation provisions for certain master trusts and group personal pensions, and disagreeing with the mandation compromise that the Government had put forward (which broadly mirrored the Mansion House Accord).
- Scale requirements – next was a Lords’ amendment that provided a new exemption from the scale requirements where the Regulator was satisfied that consolidation was unlikely to improve member outcomes. The Lords did not insist on their amendment but instead proposed a new amendment that was a development on their original, most notably adding a new exemption for where good outcomes as a result of innovation could be demonstrated.
- Benefits of competition – then there was a Lords’ amendment that required that when making regulations in relation to the scale and mandation requirements, the Government must have regard to the encouragement of innovation in the design and operation of pension schemes and the benefits of competition among providers of pension schemes. The Lords did not insist on their amendment but instead proposed a new amendment that removed the encouragement of innovation aspect.
- Public service pensions – finally, the Lords insisted that their amendment requiring a review of public service pension schemes in relation to their long-term affordability, intergenerational fairness, fiscal sustainability, and accounting treatment, be considered again by the Commons.
The House of Lords did not contest other non-Government amendments it had made that had been removed by the Commons.
In response, the Government has proposed to vote all the Lords’ amendments down, but in their place substitute the following which will likely be passed by the Commons on 22 April 2026:
- Mandation – a number of changes, the highlights of which are:
- the restoration of the Government’s compromise asset allocation mandation provision,
- newly the power only being able to be used once and only with regards to the main default fund,
- the sunset for the use of the power being brought forward from the end of 2035 to the end of 2032, and
- perhaps most significantly of all, the legislation relating to the power being repealed by the end of 2035, so that even if the Government uses the power, impacted schemes will not be subject to it after the end of 2035.
- Scale requirements – a requirement for the Government to publish a report about the effects of consolidation on innovation in the design and operation of relevant master trusts and group personal pension schemes within a year of when this part of the Bill comes into force.
- Benefits of competition, innovation and good governance – new provisions relating to the auto-enrolment quality requirements for master trusts and group personal pension schemes and default arrangements for DC schemes generally to the effect that regulations for both must have regard to the importance of innovation in the design and operation of schemes, competition amongst schemes, improving outcomes for members of schemes, achieving scale (for master trusts and group personal pensions only) and having effective governance.
- Public service pensions – a much more restricted review of public service pension schemes (excluding local government workers pension schemes) to be undertaken by the Government Actuary, comprising cash flow projections for each of the next 50 years.
Assuming this comes to pass, the Bill goes back to the Lords once more!
Comment
As has been clear from the time that the Bill first reached the Lords, it is the possibility of Government forcing certain asset allocation requirements on the largest of DC schemes that most concerns the Lords. It is not clear at this point whether the Government has done enough to assuage the concerns held on this topic by the Lords, despite the number of concessions it is proposing.
PASA guidance on contingent spouse pension data and calculation approaches
The Pensions Administration Standards Association (PASA) has published new guidance that sets out a framework for assessing, calculating and maintaining contingent spouse pension (CSP) amounts, focusing on pensioner members due to the increased complexity of calculations for these members. The CSP is a pension payable under scheme rules to a surviving spouse, civil partner or other qualifying dependant upon the death of a DB scheme member, whether in active service, deferment, or retirement.
Determining contingent spouse pension amounts is critical not only for insurer transactions (both for initial pricing and completion), but also for effective ongoing administration, actuarial valuation, regulatory readiness (both for the pension dashboard and for scheme-specific data expectations under TPR guidance) and, most importantly, ensuring dependants receive the correct benefits at the appropriate time.
After looking at data considerations, including assessment of accuracy and some areas that will require additional consideration, the guidance sets out five approaches – from first principles calculations to pragmatic estimation techniques – enabling schemes to select an approach aligned with data availability, purpose and scheme complexity.
Comment
The need for this guidance reflects the fact that complete and reliable contingent spouse pension amounts may not always be held electronically for pensioner members, with detailed calculations taking place only if a survivor’s pension needs to be put into payment.
The guidance will be of interest to those carrying out data improvement exercises and provides an insight to those commissioning them into how complex such exercises may be. It also makes clear that, even if possible, complete accuracy may not be needed, depending on the purpose of the data improvement exercise.
Fraud Minister’s plea to trustees and administrators
The Fraud Minister, Lord Hanson, has urged trustees and pension scheme administrators to “use every touchpoint” to reinforce scam warning messaging with scheme members.
Speaking at the Pension Scams Action Group’s Fighting Pension Fraud webinar 2026, Lord Hanson reminded attendees that scheme members may not recognise the warning signs that trustees and administrators are likely to be more alert to and that reinforcing “the importance of stopping and thinking before sharing personal information on their life savings” was crucial.
Echoing this, HMRC has issued a timely reminder that pensioners should be alert to scams associated with the recovery of 2025 Winter Fuel Payments that is due to get underway this month from pensioners with income above £35,000 pa. Although in most cases these payments will be recovered via changes to PAYE tax codes, HMRC – which has seen more than 25,000 Winter Fuel Payment scam referrals over the last 12 months – is warning that scammers may use the recovery process as a hook to target those affected.
Emma Douglas appointed new Chair of The Pensions Regulator
The Department for Work and Pensions has announced the appointment of Emma Douglas as the new Chair of The Pensions Regulator (TPR). Ms Douglas had been the Government’s preferred candidate and was endorsed by the Work and Pensions Committee at the start of the year (see Pensions Bulletin 2026/03).
The Government’s announcement notes that Ms Douglas has more than 25 years’ experience in the investment management and pensions industry, including as Wealth Policy Director at Aviva and is the current Chair of the Pensions UK Board.
Ms Douglas will start her term on 1 July 2026, when Kirstin Baker, the interim Chair, steps down.
Comment
Ms Douglas is a well-known and respected expert in the pensions industry. We wish her the best in this new role and look forward to continuing to work with her.
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