Pensions Bulletin 2026/17
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This edition: Royal Assent achieved for the Pension Schemes Bill after last minute changes to mandation, LCP publishes Pensions Powerbrokers 2: the DC generation, LCP’s latest Master Trusts Unpacked report published and more.

Royal Assent achieved for the Pension Schemes Bill after last minute changes to mandation
The Pension Schemes Bill completed its final stages in Parliament this week receiving Royal Assent on 29 April 2026 as part of the prorogation of Parliament that took place on the same day. However, it was a close-run thing, with the House of Lords keeping up their opposition to mandation right up until the evening of 28 April 2026, agreeing to bring several sessions of ping-pong to a conclusion only when last minute amendments were made to the Bill in the Commons earlier that day.
The concessions extracted this week by the Lords in relation to the Government’s reserve power that would enable it to mandate asset allocation for DC Master Trusts and group personal pensions included the following:
- Limiting those qualifying assets for which mandation can apply to private equity, venture capital, private credit, interests in land, infrastructure, and unlisted equity securities not falling within the above five categories (until now mandation could have applied to any asset class) – and requiring clear descriptions of each of these six categories to be set out in regulations;
- Strengthening the nature of the report the Government must prepare and publish before activating the mandation requirement. The strengthening includes the report now having to contain:
- a joint assessment by the FCA and the Pensions Regulator of the extent to which there is evidence of competitive conditions restricting relevant Master Trusts and group personal pension schemes from investing in qualifying assets, including in circumstances where such investments may be in the best interests of members of such schemes;
- the Government’s assessment of the extent to which relevant Master Trusts and group personal pension schemes have made progress towards achieving 10% (by value) of scheme assets held in main default funds to be qualifying assets, and 5% (by value) of scheme assets so held to be of a UK-specific description;
- the Government’s assessment of any barriers to relevant Master Trusts or group personal pension schemes investing in qualifying assets, including in particular where such assets are located in the UK.
- Not allowing regulations that will set the mandation percentages to be made before 1 January 2028.
- Making it easier for impacted Master Trusts and group personal pension schemes to have mandation suspended – in particular, the test is to be that mandation is not in the best interest of members rather than as previously that it would cause members material financial detriment. Also, that the FCA or Pensions Regulator as appropriate only has to come to the view that it is reasonable for the applicant to have reached that conclusion, rather than it reaching its own view on the matter.
All the above build on concessions achieved last week (see Pensions Bulletin 2026/16).
Comment
The Lords continued opposition to mandation did not in the end result in it being struck from the Bill, but at least a number of the hard edges in the Government’s proposals have been addressed in what is a compromise between the two Houses.
LCP publishes Pensions Powerbrokers 2: the DC generation
We have published a significant report which examines where DC pension assets are held, the crucial role trustees play in managing them – and what this means for the current market, members, and sponsors.
The research finds that more than half of all the money in occupational DC pensions – over £160bn – is controlled by fewer than 50 trustees.
The report explores five key questions:
- What issues arise from the consolidation of power in the hands of a small number of people? How are such trustees best supported to fulfil this increasingly challenging task, and how to ensure diversity of insight and action?
- Has provider power remained important?
- How is the role of DC trustees evolving and becoming more challenging?
- Is the employer voice becoming ‘muffled’?
- Is the member voice becoming quieter?
Comment
The concentration of power in a relatively small number of people is not necessarily either good or bad. However, it does raise important questions about the direction of travel in DC – particularly regarding consolidation – and the challenges of ensuring that the DC trustees of the future are sufficiently qualified, independent, supported and accountable to deliver high quality outcomes for millions of DC savers.
LCP’s latest Master Trusts Unpacked report published
LCP’s latest analysis of the master trust and broader provider market highlights improvements in the quality of service members are receiving and shows that providers are developing a range of solutions as decumulation options increase. The report covers pension providers managing more than £700 billion of workplace pension assets across all arrangements, representing an estimated 85–90% of the total market. It focuses on key areas outside of investments that have an impact on a DC savers’ experience and ultimate outcomes including:
- How the market continues to develop
- The continued evolution of post-retirement offerings
- Improving service standards
The main findings are as follows:
- Seven providers currently have a default fund of more than £25 billion (as will be required by 2030).
- Encouraging progress being made towards the default retirement solutions that master trusts (and others) will be required to offer next year.
- Improved member service performance.
Other findings include:
- Only half of the providers LCP receives data from have seen an increase in call volumes, despite growing memberships across the board.
- While most providers have some presence across social platforms, there is still clear room for improvement.
- The provider landscape is continuing to change, with continuous developments and enhancements to propositions for the benefit of employers and members.
- The Government’s reforms in the Pension Schemes Bill are likely to result in further consolidation of the master trust market, despite transition plans for those that won’t ‘make the cut’ by 2030.
Comment
While developments in this sector appear overall positive, it remains to be seen how resilient the various master trust models will be and how they will adapt to the forthcoming legislative challenges.
Pensions Regulator publishes new dashboard materials
There has been quite a bit of activity concerning dashboards from the Pensions Regulator this week all brought together through a blog that sets out latest thinking on connection and beyond.
The blog first links to a new market oversight report following the Regulator reaching out last year to the largest occupational pension schemes to assess their data preparations. This report has the following highlights:
- Most large schemes are already connected and have increased their focus on data.
- Personal data work, used to identify dashboard users, is ongoing.
- Value data preparations lag behind personal data, with significant work still required to ensure information sent to members is accurate, up‑to‑date and dashboard‑ready.
- Data quality controls exist but must mature, with schemes needing to embed data improvement, monitoring and assurance into business‑as‑usual activity rather than treating it as a one‑off exercise.
The blog then says that the Regulator has also updated its guidance to highlight good practice, the progress made by the Money and Pensions Service on the digital architecture and to provide clarity on areas they are often asked about. It has also provided two checklists to help schemes prepare for dashboards: one for schemes which are still working to connect, and one for schemes which are already connected.
The Pension Management Institute has also published its 2026 Pensions Dashboard Guide with the message that it is vital that schemes are data ready.
PASA issues new guidance on default retirement solutions
The Pensions Administration Standards Association (PASA) has published new guidance exploring the significant operational challenges facing administrators as default retirement solutions are introduced by the Pension Schemes Bill.
The paper sets out how upcoming guided retirement duties will reshape DC administration. It warns that without early planning and close collaboration across the industry, operational constraints could limit the success of reforms designed to improve retirement outcomes.
The guidance focuses on the practical realities of delivery, highlighting the scale of change required across systems, processes and governance frameworks. It emphasises administration will play a critical role in determining whether policy ambitions translate into better outcomes for savers. PASA also identifies a number of key risks, including system strain, data challenges, increased complexity and the need to support vulnerable or disengaged members more effectively.
Comment
As PASA notes in its guidance the currently proposed timeline for implementation is tight with current expectations that this requirement will apply from 2027 for master trusts and for single employer DC schemes and GPPs from 2028. Therefore, this guidance is a welcome prompt for those involved with the delivery of these solutions.
HMRC looks ahead to NMPA transitional regulations
As promised in February 2026 (see Pensions Bulletin 2026/09) HMRC has shared some detail in Newsletter 180 on what we can expect to see in transitional regulations relating to the increase in normal minimum pension age (NMPA) to 57 that takes effect on 6 April 2028. These regulations will enable individuals who have met all the conditions to access benefits while NMPA is 55 to continue to do so seamlessly when NMPA increases to 57 even if they have not yet reached that age on 6 April 2028.
The Newsletter illustrates the transitional provisions that are likely to be put in place by way of a series of examples covering a variety of scenarios including where pension payments have started before 6 April 2028, and where the member became entitled to authorised benefits before 6 April 2028 but first payment is made thereafter.
Other examples consider the treatment of uncrystallised funds lump sums (UPFLS), transfers of pensions in payment and payments to members of qualifying recognised overseas pension schemes.
HMRC does stress that the information provided is provisional and could change before the regulations are finalised for technical consultation. It also emphasises that while tax legislation sets the NMPA, this must always be considered alongside the rules of each pension scheme, which determine what benefits are available and from what age. In some cases, scheme rules may specify a higher minimum age than NMPA.
On other matters the Newsletter:
- highlights actions that must now be taken by pension scheme administrators who have yet to migrate their schemes to the “Managing pension schemes service”; and
- reminds readers about completing pension scheme returns, looking up lifetime allowance protection enhancements, using consolidated relief at source references (where these have been obtained) and submitting annual relief at source returns.
The Newsletter concludes with details of the tax repayment claims received in the first quarter of 2026 and the 2,421 applications to register new schemes received in 2025/26.
Comment
We are pleased to see that HMRC has sought to address the concerns that members who are now nearing age 55 and weighing up their retirement options may have in light of the lack of clarity over how any benefits drawn might be treated after the NMPA increases. It is however rather perplexing as to why the regulations themselves are not yet available, given that – as HMRC acknowledges – similar transitional provisions were put in place when the NMPA increased from age 50 to age 55 in 2010. We hope to see the draft regulations made available for technical consultation imminently.
Pensions Ombudsman sets out its approach to McCloud complaints
In 2015 changes were made to public sector pension schemes with transitional provisions for older members, but in the McCloud and Sargeant cases the transitional provisions were found to be unlawful age discrimination. In 2022 the Pensions Ombudsman stated (see Pensions Bulletin 2022/29) that it would not usually investigate complaints in this area while the government devised a suitable remedy.
The McCloud remedy is now in place and the Ombudsman has set out its approach to dealing with any related complaints in a slide deck. It states that it expects schemes to be making progress and have an organised approach to dealing with remedy implementation.
The Ombudsman aims to deal with McCloud complaints by producing “significant Determinations” on cases concerning an issue or issues affecting several members across several schemes. These will set out the Ombudsman’s position on key McCloud issues and inform the approach schemes should take in resolving Ombudsman complaints internally. If internal resolution is not possible then the Ombudsman will still be able to investigate complaints. The Ombudsman will also individually deal with cases that are different to the significant Determinations.
Comment
This seems like a very sensible approach for the Ombudsman to take. This development may be of interest to sponsors and trustees of private sector schemes operated by outsourcing providers that replicate public sector benefits.
Nest now empowered to provide flexi-access drawdown
An Order has now been laid before Parliament in final form that enables Nest to offer flexi-access drawdown, and other relevant options, as benefits to its members. The National Employment Savings Trust (Amendment) Order 2026 (SI 2026/449) came into force on 29 April 2026.
On the same day, consultation closed on changes to the Nest Rules (see Pensions Bulletin 2026/10) that will introduce flexi-access drawdown.
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