Pensions Bulletin 2026/26

TPR begins contacting DC schemes on readiness for the Pension Schemes Act 2026 

The latest blog from The Pensions Regulator (TPR), written by Kim Goodall-Brown, Director of DC and Master Trust Supervision, sets out its expectations on DC schemes to deliver better outcomes to members, now that the Pension Schemes Act 2026 has come into law. 

The blog explains that TPR has emailed many DC schemes this week encouraging trustees to reflect on their scheme’s ability to comply with the new requirements and start to prepare, targeting schemes providing DC benefits that are likely to need to comply. Further update emails will be sent out regularly with further details on a new TPR webpage. 

After summarising the new legal duties for DC schemes (see also LCP’s guide to the Act) TPR warns that it does not expect all DC schemes, particularly smaller schemes, to be able to meet the requirements and that trustees should be asking whether it is in their members’ best interests to continue running the scheme. 

HMRC Newsletter 182 highlights changes to ID verification procedures 

HMRC’s Pension Schemes Newsletter 182 highlights that with effect from 8 May 2026 the identity verification process for individual scheme administrators and practitioners enrolling on to the managing pension schemes service has been updated to remove the option to manually enter passport and driving licence details. Instead, validation must now be via the GOV.UK ID Check app alongside a scan of valid photo ID. HMRC says that the process has been updated to prevent the risk of fraud and align with UK government and international standards. 

The Newsletter goes on to announce a further delay to the strategic payment service intended to support faster payment processing for pension schemes that claim relief at source. Initially promised for April 2026, then delayed to summer 2026 (see Pensions Bulletin 2026/09), it is now not expected to be operational until “later in 2026”.  

The Newsletter also notes the ongoing technical consultation on draft regulations covering guaranteed minimum pension conversion provisions (see Pensions Bulletin 2026/23), discusses processes around relief at source claims and links to guidance clarifying reporting requirements for employers reporting employee pension contributions to HMRC. 

Government consults on family law reforms

The Ministry of Justice has published a consultation - A fairer end to relationships – on wide-ranging reforms to the law of England and Wales governing financial arrangements when relationships end. This follows on from the Law Commission review in 2024 looking at how finances are divided when couples end their marriage or civil partnership (see Pensions Bulletin 2025/01).

For divorce and civil partnership dissolution a “codification plus” model is proposed, putting established case law principles including “needs” and “sharing” on to a statutory footing. As part of this family law courts would be specifically required to consider both parties’ pension needs when making financial orders. An express obligation to consider pensions accrued during the marriage is also proposed. The Government has rejected a suggestion from the Law Commission review that pensions accrued during a marriage should be equally shared by the court by default, instead preferring to enable the court’s discretion in determining the appropriate distribution of resources when seeking to address the couple’s individual needs.

The consultation also proposes the introduction of binding “qualifying nuptial agreements”, allowing couples to make binding arrangements in advance about financial outcomes on divorce, albeit subject to a financial needs test (including perhaps pensions).

The consultation also proposes codifying the principle that a period of seamless cohabitation before marriage can count towards the length of the marriage for the purposes of financial awards, including pension sharing orders.

Finally, and not pensions-related, the consultation proposes that cohabitees are put to the top of the priority order, alongside spouses and civil partners when a person dies without a will. However, the consultation makes no proposals about changes to inheritance (or other) tax law in respect of this.

Consultation closes on 14 August 2026.

Final LTA abolition regulations now made

The Pensions (Abolition of Lifetime Allowance Charge etc) Regulations 2026 which were laid before Parliament at the start of June (see Pensions Bulletin 2026/22) have now been made and came into effect on 25 June 2026.

This is the fourth – and last possible – set of regulations made to address technical errors and omissions in the complex legislation surrounding the abolition of the Lifetime Allowance with effect from 6 April 2024 as the power to make changes to the primary legislation by statutory instrument expired on 30 June 2026.

TPR reports steady progress with dashboard and VFM tests ahead – and higher spending

The Pensions Regulator (TPR) has published its 2025/26 annual report and accounts. TPR says that it has continued to evolve its approach, while delivering against its corporate plan (see Pensions Bulletin 2025/29).

The performance framework has changed, making a year-on-year comparison with 2024/25 less straightforward. Last year (also covered in Pensions Bulletin 2025/29) TPR reported 28 targets achieved or on track, three marginal misses and one significant miss, the latter relating to cyber risks and technology in the pensions sector. This year, TPR says it is assessing performance against 32 corporate priorities using 35 indicators, including five growth commitments. It uses a “red, amber, green” framework for this.

At the headline outcome level, most areas are reported as green. Automatic enrolment compliance remained strong, with 97.8% of employers ultimately compliant with their enrolment or re-enrolment duties, against a 90% target, and 97.1% making timely and accurate pension contributions. TPR also reports that more than 1,300 schemes and providers are now connected to the pensions dashboards central digital architecture, representing over 40 million memberships.

There are, however, some amber notes. TPR rates its “fewer schemes, delivering good outcomes” priority amber, mainly because progress on the value for money framework remains dependent on external decisions and the legislative timetable. A further amber rating relates to delays in delivering a new automatic enrolment re-declaration journey for low-risk employers, intended to reduce regulatory burdens.

TPR’s own costs continue to grow. It spent £115.2m in 2025/26, compared with £104.8m in 2024/25, and was £3.9m below budget. This compares with last year’s spend of £104.8m and an underspend of £7.1m. TPR says the latest underspend reflected lower spending on digital work and commissioned research, and that it has agreed a three-year funding settlement with DWP, including a 2% efficiency target in each spending review year.

Headcount also edged up. The average number of whole-time equivalent staff was 995 in 2025/26, compared with 974 in 2024/25, although off-payroll staff reduced from 83 to 62 as transformation activity completed and TPR’s risk-based regulatory approach became embedded.