Pensions Bulletin 2026/25
This content is AI generated, click here to find out more about Transpose™.
For terms of use click here.
This edition: PDP softens dashboards reporting timetable, but the pressure to prepare remains, Regulator blog on DB endgame innovation, Regulations extend HMRC’s obligation to top-up tax relief to those in “net pay” arrangements and more.
PDP softens dashboards reporting timetable, but the pressure to prepare remains
The Pensions Dashboards Programme (PDP) has published the outcome of its consultation on revised reporting standards for pensions dashboards, in which PDP proposed changing the way operational data is provided to the Money and Pensions Service (MaPS) (see Pensions Bulletin 2026/05). This change affects the timetable for routine operational reporting to MaPS rather than the core dashboards data duties themselves.
Under the current reporting standards, schemes and providers generally need to generate and retain certain operational data so that it can be provided to the MaPS on request. The consultation proposed moving that reporting to a regime of routine daily submission, while not changing the fundamental data that must be generated and recorded.
In the consultation outcome, the PDP recognises that the original timetable was ambitious. The PDP intends to enable daily reporting before the end of November 2026 but extend the implementation deadline to 1 March 2027. In the meantime, the PDP expects to require some manual reporting from affected schemes at regular intervals from this autumn before the final automated process is in place.
Comment
In one sense, this is a helpful and sensible development. A timetable that is not realistically deliverable helps nobody, and a modest delay may improve the chances of firms implementing the reporting regime properly rather than hurriedly. But schemes and providers should resist the temptation to treat this as breathing space and to pause preparation. The move to routine reporting still represents an important change in the operational expectations around dashboards, and those who have not yet worked through the data requirements should use this period to do so.
Regulator blog on DB endgame innovation
Following last week’s ministerial statement on the DB pensions regulation (see Pensions Bulletin 2026/24) Ben Gunnee, Executive Director of Market Oversight at the Pensions Regulator has published a blog, New thinking for trustees considering endgame solutions for defined benefit schemes.
Mr Gunnee notes the transformation in the DB funding landscape with 80% of schemes in surplus on a low dependency basis as at the end of September 2025, with an estimated £170bn of surplus assets. This has generated changes in trustee thinking and market innovation, most notably last year’s transaction involving the Stagecoach Group Pension Scheme. The blog describes the Regulator’s approach to this transaction. It also comments on the use of “flexible apportionment arrangements” (FAAs) following the ministerial statement that these are under review, stating both that they consider the forthcoming consultation announced last week to be an important opportunity for industry stakeholders to “help shape a proportionate and effective approach” and that they will need to consider an interim approach to transactions involving FAAs that present similar characteristics to the Stagecoach deal. The Regulator will also work alongside the Department for Work and Pensions “to ensure that the regulatory framework evolves in step with the market”.
The blog finishes by stating that the Regulator wants to support innovation while ensuring that the guard rails are in place for this to happen safely and by reminding that anyone considering new models or novel proposals should engage with the Regulator via its innovation support service.
Comment
While this is not formal guidance, it offers a helpful insight into current Regulator thinking. The remark about an interim approach to FAAs could be significant. The language used around developing "proportionate" approaches to supporting innovation is noteworthy as is the overarching message that anyone considering new models or novel proposals engages with the Regulator early on.
Regulations extend HMRC’s obligation to top-up tax relief to those in “net pay” arrangements
Regulations have been laid that amend the Finance Act 2004 to extend HMRC’s obligation to make a top-up payment to individuals with pensions administered under “net pay” arrangements where they obtain less tax relief than they would have done had their pension been administered under “relief at source” arrangements.
In a net pay arrangement, pension contributions are deducted from earnings before tax is calculated, so individuals only receive tax relief to the extent that they have taxable income. This contrasts with individuals saving under relief at source who receive a top-up into their pension scheme equivalent to basic rate tax regardless of whether they have an income tax liability. Provisions introduced by the Finance Act 2023 required HMRC to make top-up payments to individuals whose total taxable income is below the personal allowance (see Pensions Bulletin 2023/13). However, this did not fully address the disparities between schemes administered under net pay arrangements and schemes administered under relief at source arrangements as there are still individuals whose total taxable income exceeds the personal allowance who will also be receiving less relief under net pay arrangements than they would have done under relief at source arrangements.
The Registered Pension Schemes (Net Pay Arrangements) Regulations 2026 address this disparity by extending HMRC’s obligation to remove these disparities and come into force on 14 July 2026. We understand that HMRC will identify eligible individuals using existing information from pension schemes and employers and will contact eligible individuals directly to arrange payment.
Comment
We welcome this move by HMRC to ensure that the correct tax relief on pensions contributions is delivered to those entitled to it regardless of the type of arrangement they save into.
PPF Levy regulations made
The Pension Schemes Act 2026 received Royal Assent on 29 April 2026. However, some parts of the Act required secondary legislation before they are in force; the changes to the “pension protection levy” being one such part (see Pensions Bulletin 2026/19).
The Pension Schemes Act 2026 (Commencement No. 1) Regulations 2026 was made on 22 June 2026 and gives the PPF the ability from 29 June 2026 to restart levy charging following a period of zero levies, which in turn gives them more flexibility to set a zero levy for this year and potentially future years (see our guide for details).
This does not cover the separate Act provisions relating to the PPF, including the indexation of pre-1997 compensation (which is still awaiting enabling regulations) and the removal of the PPF administration levy mechanism (which has already taken place).
Comment
This set of commencement regulations, while essential, is just a formal step as the PPF had already taken the regulatory changes as read even before the Bill was enacted (see Pensions Bulletin 2026/12).
To keep track of the progress of the many different topics, please see our Pension Schemes Act 2026 hub.
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 Jon Forsyth 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.
