Issues affecting all schemes
Pensions dashboards – finalised standards and guidance
The following dashboards standards have been finalised and have received ministerial approval:
- Code of connection – This sets out how schemes and dashboard providers are to connect to the dashboards ecosystem and what they need to do to remain connected.
- Technical standards – These provide a common set of connection rules for pension providers and schemes, determining how parties are to interact and communicate with the dashboards ecosystem’s central digital architecture and each other.
- Data standards – These set out the data formatting requirements that schemes must follow when returning pensions data in response to view requests.
- Reporting standards – These set out the requirements that schemes must comply with in relation to recording of operational information and the reporting of that information to the Money and Pensions Service.
In addition, the Pensions Dashboards Programme (PDP) has published:
- A blog post on what schemes need to do ahead of connection to the dashboards ecosystem.
- Guidance and FAQs on connecting to the dashboards ecosystem via a third party.
- Guidance on notifying their regulator and the PDP if the scheme plans to connect more than 30 days before or after its target “connect by” date in the government’s statutory guidance.
- Guidance and FAQs on integration testing.
- A blog post on system testing resources for schemes planning to connect directly to the dashboards ecosystem.
Action
Trustees and administrators should review the finalised standards and factor them into their dashboards preparations. They may also find the various PDP publications helpful.
Company directors – guidance on identity verification
Companies House has published guidance on how individuals who will be subject to the identity verification requirement under the Economic Crime and Corporate Transparency Act 2023 (ECCTA) can verify their identity. Those who will be subject to the requirement include directors, persons with significant control and individuals filing documents at Companies House on behalf of a company. The guidance covers:
- Why individuals need to verify their identity.
- Who needs to verify.
- When individuals need to verify.
- Ways to verify.
- What happens when individuals verify.
- What individuals need to do with their Companies House personal code.
- What happens if individuals do not verify.
For more information on the new requirements being introduced by ECCTA, please see our legal update.
Action
Trustee companies should speak to their company secretarial services provider (or whoever normally carries out their company filings) to confirm that they are aware of the changes and that steps will be taken to ensure compliance with the new requirements by the trustee company and its directors.
Pensions tax – Finance Act 2025 and Spring Statement
The Finance Act 2025 has received Royal Assent. Its pensions-related provisions include:
- Removal of the exemption from the overseas transfer charge for transfers to qualifying recognised overseas pension schemes in the EEA or Gibraltar with effect from 30 October 2024.
- Introduction of a requirement for scheme administrators (for tax purposes) to be UK resident with effect from 6 April 2026.
The Spring Statement 2025 did not contain any pensions-related announcements.
Action
Trustees should confirm that their scheme administrator for tax purposes is UK resident.
Pensions Regulator – data strategy
The Pensions Regulator (TPR) has published a strategy to raise standards around data to improve outcomes and benefit the wider market through increased efficiencies, enhanced innovation and reduced regulatory burden. Under the strategy, TPR will focus on three key areas:
- Building strong foundations by implementing data principles, developing forward-thinking data professionals, and advocating for open standards for data to collect, analyse, and interpret high-quality data for better decision-making.
- Taking a wider data approach and reducing regulatory burden by creating an internal data marketplace that links to the government’s National Data Library and the wider external data ecosystem.
- Focusing on adding value by making sure all the data TPR collects is directly related to good member outcomes and supports efficient and effective regulation, competition and industry innovation.
The strategy goes on to set out TPR’s planned initiatives in these areas, including establishing an AI advisory council to oversee the ethical use of AI technologies. TPR notes that a flexible, adaptive approach to strategy development is required and that elements of its strategy will therefore develop at different paces. TPR expects the strategy to mean higher expectations of the pensions industry, but also more modern data practices which will reduce regulatory burdens and enable more effective market competition.
Action
No action required.
Supporting economic growth – TPR pledges
The government has published an action plan to ensure the UK’s regulators and regulation support economic growth in the UK. As part of the plan, TPR has pledged to:
- Increase the value of pension funds.
- Enable productive investment.
- Reduce unnecessary regulatory burden and release funds for investment.
- Drive growth through data and digital enablement.
- Support market innovation.
Action
No action required.
Issues affecting DB schemes
Virgin Media – update on government intervention
The Pensions Minister has said that the government has not made any final decisions on whether it will take action in light of the Virgin Media ruling. The government is actively considering its next steps and will provide an update in due course.
In addition, a case was recently heard in the High Court which we understand may have covered various issues arising out of the Virgin Media ruling. We understand that the High Court judgment in this case may not be available until the autumn.
Action
No action required.
Issues affecting DC schemes
Pensions review – update on second phase
The Pensions Minister has confirmed that the second phase of the government’s pensions review, which will look at pensions adequacy, will take place “in due course”.
Action
No action required.
Mayer Brown news
Mayer Brown media comment
- Andrew Block was quoted in an article by Investment and Pensions Europe on the extent to which section 58B Pensions Act 2004 affects the ability of UK pension scheme trustees to invest in line with the UK government’s growth agenda.
Mayer Brown Insights
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