Pensions Bulletin 2026/33
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This edition: TPR publishes VFM overview documents and Explanatory Notes published for the Pension Schemes Act 2026.

TPR publishes VFM overview documents
The Pensions Regulator (TPR) has added two documents about the forthcoming Value for Money (VFM) framework to its Pension Schemes Act 2026 webpage.
The first of these is an overview of the proposed VFM requirements that TPR says “has been created to help trustees better understand the latest proposals” currently under consultation (see Pensions Bulletin 2026/28 – but note that DWP recently announced that the consultation is being extended by two weeks and will now close on 15 September).
The second document is a technical overview of the proposed VFM digital service, also known as the VFM database. The service is intended to provide a central platform for submitting standardised VFM metrics, accessing comparator data and submitting assessment outcomes, replacing the previously proposed self-published and comparison approach. The service is planned for launch in 2028, with testing and development continuing through 2026 and 2027.
Comment
As well as engaging with the current consultation, trustees and scheme managers should monitor the development of the VFM digital service. This will be the interface of the VFM framework and schemes will have to ensure their data collection, operational processes and governance can meet the requirements.
Explanatory Notes now available for the Pension Schemes Act 2026
The Department for Work and Pensions has made available the Explanatory Notes to the Pension Schemes Act 2026. These aim to help readers understand what each part of the Act will mean in practice and provide additional information on how the Act will affect existing legislation. The DWP expects the notes “to assist the reader of the Act and to help inform debate on it”. However, in many areas the operative detail, scope and timing will depend on secondary legislation and regulatory rules still to come.
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