Pensions Bulletin 2026/36

DWP consults on GMP conversion regulations

The Government is consulting on amendments intended to make Guaranteed Minimum Pension (GMP) conversion easier to implement, by simplifying and clarifying rules, particularly for schemes undertaking individual rather than bulk conversions. The proposals are largely operational and are not intended to reduce members' accrued benefits and build on the basis of GMP conversion set out in the Pension Schemes (Conversion of Guaranteed Minimum Pensions) Act 2022 (see Pensions Bulletin 2022/17).

The key proposals are:

• Clarification of survivor benefits: The regulations seek to clarify that the minimum survivor's pension following GMP conversion would generally be based on half of the member's relevant converted pension, rather than half of the value of the pension the member’s relevant pre-conversion pension. This is not a change from the current position in legislation. They also seek to clarify in what circumstances such a survivor’s pension needs to be provided.
• Simplified employer consent: The regulations would clarify which employers need to consent to GMP conversion by introducing the concept of a “relevant person”. In practice, this would be an employer with financial responsibility to the scheme at the time of conversion, rather than historical employers that no longer have any continuing connection. For schemes with multiple relevant employers, those employers could unanimously agree that one employer acts on behalf of all of them.
• New approach to actuarial certification: An important proposed change would allow an optional model-based approach for individual GMP conversions. Rather than requiring the scheme actuary to certify each individual conversion, the actuary could certify the methodology and model used to calculate the conversion. The model would need ongoing oversight, including at least annual review and re-certification, with cases outside its scope requiring separate actuarial consideration. This could materially reduce administration and actuarial costs for schemes carrying out large numbers of individual “at retirement” conversions.
• Transitional arrangements: The proposals are not intended to require completed GMP conversion exercises to be reopened. Schemes already part-way through an exercise may be able to continue under the existing rules where member consultation has already commenced, subject to the proposed transitional provisions.

Trustees should consider whether the proposed changes could affect the scheme's GMP equalisation and conversion strategy or timetable and also whether their scheme could benefit from the new approach to actuarial certification.

Importantly, schemes currently undertaking GMP conversion should specifically obtain advice on the transitional provisions and whether it would be advantageous to adopt any of the proposed new processes once the regulations take effect.

This consultation follows on from a consultation by HMRC (see Pensions Bulletin 2026/23) seeking to address the remaining pensions tax issues associated with GMP conversion. The consultation closes on 29 October 2026.

DWP proposes to keep GMP fixed rate revaluation at same rate

The DWP is consulting on keeping the fixed rate of Guaranteed Minimum Pension (GMP) revaluation at 3.25% pa for those leaving pensionable service between 6 April 2027 and 5 April 2032.

The revaluation rate is reviewed every five years (see Pensions Bulletin 2021/40), and a new rate needs to be applied for those who leave pensionable service on or after 6 April 2027. DWP has always undertaken this review after having taken advice from the Government Actuary’s Department (GAD) on the rate that should apply. The consultation closes on 29 October 2026.

TPR updates its enforcement approach

The Pensions Regulator (TPR) has published its finalised enforcement approach, following last year’s consultation on proposals to make its enforcement activity more targeted, proactive and outcomes-focused (see Pensions Bulletin 2025/37).

The final approach retains the direction set out in the consultation, with TPR prioritising cases according to their impact, scale and complexity and seeking to intervene earlier where this can prevent harm. It also provides further detail on its approach to serious economic crime, the role of data and technology, and the outcomes it seeks from enforcement.

TPR says its enforcement activity will seek to achieve four broad outcomes: prevention, reparation, accountability and member confidence. Its toolkit ranges from supervisory engagement and guidance through to directions, fines, trustee prohibition and prosecution.

PASA launches new Guided Retirement Operational Readiness Guidance

The Pensions Administration Standards Association (PASA) has published new guidance on operational readiness for Guided Retirement, designed to help trustees, administrators and providers assess their readiness to deliver guided retirement in practice.

The central message is that schemes should start preparing for Guided Retirement now, even though the final policy framework is still evolving and implementation is not expected until 2029 (at the earliest – see Pensions Bulletin 2026/28).

PASA argues that Guided Retirement should not be treated simply as the creation of a new retirement product. It is an operational transformation affecting the whole member journey — particularly administration systems, data, governance, communications and payment processes.

PASA suggests that operational readiness should be tested through five practical questions, focusing in particular on four critical building blocks: systems, data, governance and member communication. It recommends a phased approach of assessing current readiness, identifying gaps and dependencies, taking sensible preparatory action where requirements are already clear, and building a scalable long-term model as the framework develops.

How pensions are like giant pumpkins!

The central message of this year’s “Pension Attention” campaign is that “growing a healthy pension takes the same ingredients as growing prize-winning produce – time, care and a little regular attention.” The campaign, organised by Pensions UK and the ABI looks at the world of competitive giant vegetable growing and compares this with growing a pension pot. This year’s campaign comes as Pensions UK highlights new research indicating that 52% of UK adults have never checked their pension pot, a third (33%) don't know what's in their pension pot and 37% don’t understand how their pension grows over time. Additionally, almost three in ten (29%) Brits admit they have no idea how much money they’ll need for retirement, and 13% say they bury their head in the soil when it comes to their pension.