Pensions Bulletin 2026/27

Pensions & benefits Policy & regulation DB pensions Pension Schemes Act Pensions dashboards

This edition: CDC Code made it in time to come into force alongside legislation, TPR looks ahead to implementation of the Pension Schemes Act 2026, Government to review pension access rules for the terminally ill and more.

CDC Code made it in time to come into force alongside legislation

The Pensions Regulator’s updated Code of Practice: authorisation and supervision of collective defined contribution (CDC) schemes will come into force on 31 July 2026, three months earlier than previously anticipated (see Pensions Bulletin 2026/18). This enables the Code to take effect on the same date as the legislation allowing unconnected multi-employer CDC schemes to apply for authorisation.

The Pensions Act 2004 (Code of Practice) (Authorisation and Supervision of Collective Defined Contribution Schemes) Appointed Day and Revocation Order 2026 was made on 2 July 2026.

Comment

It is useful for CDC schemes preparing for authorisation to have the final Code over the summer to confirm the final details before taking such a step.

TPR looks ahead to implementation of the Pension Schemes Act 2026

The Pensions Regulator (TPR) has issued its July 2026 Master Trust Bulletin to subscribers (a public version should also shortly be available here). This edition brings together previous publications by TPR, as well as setting out practical matters trustees should bear in mind, especially in light of the new Pension Schemes Act 2026 (see Pensions Bulletin 2026/17). Many of the articles are applicable to both master trust trustees and trustees of other defined contribution schemes, and the key points include:

Preparing for the next phase of pensions reform: TPR emphasises that the Act marks a decisive shift for the DC market. Master trusts will need to demonstrate value for money, support members throughout their journey into retirement, prepare for the new small pots consolidation framework and continue developing their investment strategies.
Trustee succession planning and skills: Trustees are encouraged to take a proactive approach to succession planning, ensuring boards have the skills and resilience needed to oversee increasingly complex schemes and mitigate key person risk.
Governance and disclosure: The bulletin stresses the importance of high-quality disclosures, strong governance and clear evidence that schemes are delivering good outcomes for members.
Investment developments: Several articles focus on investment governance, including evolving expectations for master trusts, enhanced investment data to support supervision, the development of Long-Term Asset Funds (LTAFs) within DC arrangements and the potential implications of tokenisation of assets.
Operational matters: The bulletin also covers good practice on sensitive payments, pensions dashboards readiness, inheritance tax reform implications, supervisory returns and the role of specialist master trust supervision.

Comment

TPR’s latest bulletin is less about announcing new regulatory requirements and more about signalling its priorities as the Pension Schemes Act 2026 moves into its implementation phase. It should not come as a surprise that trustees of master trusts can expect increasing regulatory focus on what they deliver in practice, rather than simply on compliance with new legislation.

We were also pleased to see that our recent joint session with TPR on Guided Retirement solutions and our work on the gender and ethnicity pensions gap featured in TPR’s bulletin.

Government to review pension access rules for the terminally ill

Following a House of Lords debate on 30 June 2026, the Government has confirmed that it will review the rules allowing people with a terminal illness to access private pension savings early on favourable tax terms. This follows concerns raised by peers around inconsistent current approaches, and that the current requirement for a medical practitioner to certify that an individual has less than 12 months to live may no longer be appropriate, given advances in treatment and the difficulties of making prognosis-based assessments in practice.

Comment

Although no immediate legislative changes or consultation were announced, the debate signals the potential for future reform in this area. Any changes could affect scheme administration, provider processes and member communications, particularly if eligibility moves away from a strict life expectancy test towards a broader assessment of terminal illness. The Government has not set a timetable for the review.

The PDP publishes video about what users can see and do on pensions dashboards

The Pensions Dashboards Programme (PDP) has released a short two-minute video explaining what users will be able to see on pensions dashboards, including different types of pensions and estimated retirement income, and what they can do with that information.

Comment

This video may be a useful tool to introduce the topic of dashboards to members at a high level.

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This generic note should not be relied upon for detailed advice or taken as an authoritative statement of the law. If you would like any assistance or further information, please contact the partner who usually advises you.

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