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Pensions Bulletin 2026/38

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Video - Podcast
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Pensions & benefits Advisory for master trusts and providers Policy & regulation DB pensions

This edition: TPR highlights barriers to private market investment, Consumer testing of MoneyHelper Pensions Dashboard steps up, TPR’s September Master Trust Bulletin and more.

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TPR highlights barriers to private market investment 

The Pensions Regulator (TPR) has published a market oversight report on pension scheme investment in private markets, based on engagement with more than 40 industry stakeholders.  

TPR says schemes are generally open to investing in UK private markets where it fits their investment objectives, but that a number of practical barriers remain. These include governance and knowledge gaps, fees and transparency, regulatory uncertainty, tension with perceived fiduciary duty and, importantly, a shortage of suitable investible UK opportunities. 

There is a significant difference between DB and DC. Most large DC schemes and master trusts have either invested in private markets or intend to do so, with initial strategic allocations typically around 5%-10% and some schemes targeting 20% or more by 2030. By contrast, most DB schemes have limited appetite for further investment, reflecting improved funding levels, particularly where they are moving towards an insurer transaction. Appetite for UK venture capital is also notably limited, with schemes tending to favour infrastructure, private credit, private equity and property. 

TPR sets out actions that trustees should consider taking to support their investments in private markets. These include considering the implications that the future development of the scheme may have on investment activities, improving their knowledge and understanding, assessing whether they have the time and opportunity to consider a wider range of investments, strengthening their risk management, reviewing support provided by advisers, and engaging with industry on how investment opportunities and implementation efficiencies may be achieved.

Comment

At the end of the day trustees would probably invest more in private markets, particularly UK investments, if there were lots of great investment opportunities out there with the right risk-adjusted return and liquidity characteristics for pension schemes. It does not seem that trustees are missing out on a treasure trove of untapped returns and as such the Government may continue to be disappointed that trustees are not playing ball. 

Consumer testing of MoneyHelper Pensions Dashboard steps up 

The Pensions Dashboards Programme (PDP) has provided an update on consumer testing of the MoneyHelper Pensions Dashboard, reporting encouraging initial feedback and a simplified route for members of the public to participate. 

PDP has so far run four tranches of testing, the latest of which registering over 11,000 pension matches for nearly 3,000 users between March and June 2026. PDP says that results were encouraging, and refinements were made to the dashboard following user feedback. 

From 1 September 2026, PDP has simplified the consumer-testing process. PDP is inviting schemes, providers, employers and other organisations to encourage their members, customers and employees to take part, and potential testers can complete a short consent process to access the dashboard more quickly. There is a comms toolkit available on request from PDP which contains ready-made material to use. PDP has also begun piloting a self-service approach for those working in the pensions industry, enabling providers, schemes and administrators to test the display of their own data independently. 

The update follows the MoneyHelper dashboard passing its independent Government beta Service Standard assessment, which enables the PDP to continue to work towards a public launch in the 2027/28 financial year.

Comment

This is evidence that dashboards are moving beyond connection and technical compliance towards the real-world member experience. Schemes and providers should consider whether to encourage members to participate in testing. Doing so could provide an early indication of the experience members will have when viewing their data, as well as highlighting potential data, matching or communications issues before the dashboard becomes publicly available. 

TPR’s September Master Trust Bulletin 

TPR’s September Master Trust Bulletin provides a useful round-up of its current areas of focus and, whilst primarily aimed at master trusts, a number of messages are also relevant to other trustees. 

As usual, it covers a wide range of topics, some of which have previously been announced. Articles to particularly note are: 

  • Specifically relating to operational management of master trusts: updated guidance is expected soon on system failures leading to data security or service delivery issues (a “significant event J”), and minor updates have been made to the Scheme Financial Template for post 1 September 2026 submissions. 
  • Future-proofing trustee boards: In light of the growing demands on trustee boards, TPR’s expectations of trustees of master trusts (which could also be relevant for other schemes) include rethinking the trustee skills matrix to ensure that areas such as cyber and data security, decumulation and retirement journey design and member engagement are covered. Trustee boards should also consider their capacity in effectively fulfilling their expanding responsibilities.  
  • Enhancing administration reporting - insights and best practice: TPR shares some of its key observations and practical takeaways that may help schemes improve their administration reporting. These include focusing on conciseness and using a dashboard to provide a clear, upfront summary of key risks, priorities, and performance, including comparisons with previous reporting. 
  • Trustee board and committee observations - good practice: TPR also provides some examples of good practice within trustee boards which it has observed. These include having an effective Chair, communications between sub-committees and trustee boards, self-assessment, diversity and secretariat support. 
  • Members with guaranteed benefits transferring to master trusts - case study: TPR’s newsletter concludes with a high-level case study of situations involving the transfer of members with either with-profits policies or protected tax-free cash into a master trust. Trustees of schemes with similar situations and considering transfers to a master trust will find this a useful overview of potential solutions. 

Comment

As was the case for the July Master Trust Bulletin (see Pensions Bulletin 2026/27), this is a lengthy but helpful round-up of issues that TPR believes master trust trustees should be considering, and continues to highlight TPR’s “focus on a prudential, no-surprises, regulatory approach.” 

MPs turn spotlight on auto-enrolment contributions for low earners 

The Work and Pensions Committee has launched an inquiry into how auto-enrolment could do more to deliver adequate retirement income for low earners, and who should meet the cost. This follows on from the Pensions Commission’s interim report, which highlighted that auto-enrolment has so far only been a partial success (see Pensions Bulletin 2026/20). 

The Committee notes that the Government currently has no plans to increase minimum contributions but that people on low income are more likely to be among those who are under-saving for retirement, whilst also being most exposed to any potential increase in contributions. Small businesses are also exposed to increases in the employer auto-enrolment contributions. The inquiry focuses on issues including how much auto-enrolment contributions need to increase and how any increase should be shared between employers and employees; how to balance current needs with long-term savings; the timetable for any increases; and ways to further extend auto-enrolment to the lowest earners.  

The call for evidence closes on 26 October 2026. 

Comment

The Committee’s inquiry asks the question likely to sit at the heart of the Pensions Commission’s final recommendations: how to increase pension savings for those with the least financial headroom to save? It has long been recognised that 8% on the current prescribed earnings band will not be sufficient for many people. But a future settlement will need to balance adequacy, affordability and fairness — and is likely to require gradual change over several years, as was the case when auto-enrolment was first introduced.  

ICO to become Information Commission 

Regulations have been made which confirm that, from 30 September 2026, the Information Commissioner’s Office (ICO) will become the Information Commission. This implements provisions of the Data (Use and Access) Act 2025 (see Pensions Bulletin 2025/25). 

The change restructures the data protection regulator’s governance with the appointment of seven non-executive members to its board, whilst maintaining the ICO’s existing regulatory functions and responsibilities. The organisation will also continue to be known publicly as the ICO. 

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