Pensions Bulletin 2026/18
This content is AI generated, click here to find out more about Transpose™.
For terms of use click here.
Annual funding statement for DB schemes issued
On 6 May 2026 the Pensions Regulator issued this year’s DB annual funding statement. It is the second such Statement under the new funding regime and is particularly relevant to valuation effective dates for the 12 months starting from 22 September 2025.
Please see our News Alert on this significant development that steps through and comments on the main aspects of the Statement.
Updated CDC Code of Practice laid in Parliament
The Pensions Regulator has published its latest Code of Practice on the authorisation and supervision of collective defined contribution (CDC) schemes, which was laid in Parliament in draft on 29 April 2026. This replaces the existing Code and extends its scope so that it covers both single and connected-employer schemes (as before) and unconnected multi-employer schemes, the regulations for which come into force on 31 July 2026 (see Pensions Bulletin 2026/01).
At the same time, the Regulator published its response to last December’s consultation on the Code (also see Pensions Bulletin 2026/01), showing that it has made relatively minor adjustments. These include:
- Enabling an allowance for unallocated assets within the scheme to be taken into account when considering the financial support that can be provided by the scheme proprietor and allowing the scheme proprietor to be owned by the scheme trustees. We understand that these have been made to clarify expectations about not-for-profit schemes.
- Adjustments to the fitness and propriety requirements, especially in the expectations for relevant experience of those being assessed. The Regulator also states that trustees would not normally be able to carry out the role of the chief investment officer.
- Further adjustments for clarification purposes. These include no requirement to reserve for running on as a closed scheme at the outset, and the regulatory approach to promotion and marketing.
The Regulator plans to provide guidance setting out areas including fees and assessment of IT systems before the summer, and separate guidance on promotion and marketing later this year. The Code itself is expected to come into force in mid-October, once it has passed the required amount of time in Parliament.
Comment
Whilst the changes the Regulator has made to the Code of Practice are minor in nature, there are many small updates, and it is important that those preparing to set up a multi-employer CDC scheme should look through the new Code carefully when preparing for authorisation.
Although the Code of Practice cannot be finalised until mid-October, hopefully this will just be a formality and will not prevent anyone eager to start the authorisation process to submit their application in early August as soon as the law permits after the legislation comes into force on 31 July 2026, provided they are prepared to make any adjustments or even re-submit should the Code need any (albeit very unlikely) further changes.
The National Insurance Contributions (Employer Pensions Contributions) Act 2026
We now have the National Insurance Contributions (Employer Pensions Contributions) Act, which received Royal Assent on 29 April 2026. The then Bill completed its Parliamentary stages on 25 March 2026. Regulations are awaited although these may be some time coming (see Pensions Bulletin 2026/13).
Comment
This revenue-raising measure from the Chancellor will not have effect until the 2029/30 tax year, giving employers plenty of time to revisit and in many cases likely to end, existing salary sacrifice arrangements.
Pensions dashboards connection deadline – six months to go
The Pensions Dashboards Programme has marked there now being six months to go until the final connection deadline of 31 October 2026 by urging organisations due to connect to the pensions dashboards ecosystem to keep going with their preparations.
The PDP says that over 1,000 providers and schemes are now connected to the ecosystem, meaning that around three-quarters of private pension records in scope – over 60 million in total – have been connected, alongside millions more State Pension records.
The PDP has also published a blog which answers a number of questions relating to connection issues. These include who needs to connect, when and how to connect, and voluntary connection for schemes out of scope. The blog concludes by asking schemes to review their plans, confirm their approach and take any remaining steps needed to complete connection ahead of 31 October 2026.
Comment
The final connection deadline is not the same thing as the point at which the MaPS dashboard goes live, for which at least six months’ notice must be given. There had been speculation some while back that the dashboard might have been turned on before this October, but clearly this now will not be the case.
Its curtains for the Women’s State Pension Age Bill
The Private Member’s Bill which sought to require the Government to publish measures to address the findings of the Parliamentary and Health Service Ombudsman in relation to the increase in State Pension Age as it affected certain women has been lost as a result of the prorogation of Parliament on 29 April 2026.
The Women’s State Pension Age (Ombudsman Report and Compensation Scheme) Bill was introduced by Stephen Flynn MP back in January 2025 (see Pensions Bulletin 2025/05) but made no progress since then.
Comment
The Bill was introduced after the Government took the decision, in December 2024, not to offer a compensation scheme – a decision that was revisited in November 2025 and confirmed in January 2026 (see Pensions Bulletin 2026/05), but on which campaigners are considering whether to launch a third legal challenge.
Sign up to receive our weekly bulletin
Subscribe to LCP emailsThis Pensions Bulletin does not constitute advice, nor should it be taken as an authoritative statement of the law. For further help, please contact David Everett at our London office or the partner who normally advises you.
If you would like to receive the weekly pensions bulletin automatically by email please fill in this form.
