Pensions: DC trustee agenda update – May 2025

TPR supervision of professional trustees

The Pensions Regulator (TPR) has announced that it will be extending its oversight of professional trustee (PT) firms. It will begin targeted engagement with larger PT firms in the summer, extending its approach to cover remaining firms by the end of the year. It will use this process to identify risks and appropriate mitigations and expectations.

Action: Any professional trustees should prepare to be contacted by TPR and questioned on the key focus areas.

Finance Act 2025 comes into effect

The Finance Act 2025 has received Royal Assent. In relation to pensions, the Act includes changes to bring requirements of recognised overseas schemes in the EEA and Gibraltar in line with the rest of the world. It also requires scheme administrators (for tax purposes) of UK registered schemes to be UK resident.

Action: Ensure that administrative processes (for example in relation to overseas transfers) have been updated for the changes.

Dashboards: standards published

The Pensions Dashboards Programme (PDP) has published updated versions of the standards that need to be complied with for connection to pensions dashboards. Schemes–or administrators/integrated service providers (ISPs), where they are facilitating dashboards connection–must comply with the standards to allow connection before the relevant deadline. The PDP has also published a blog post setting out guidance on dashboards connection via a third party.

Action: Ensure your scheme/administrator/ISP is on track for complying with the standards in time for your dashboards connection deadline and consider the PDP guidance.

Neonatal care leave

On April 6, 2025, a new right was introduced for employees to take up to 12 weeks’ leave if they have a child who is receiving neonatal medical care. The regulations setting out this new right include requirements in relation to pension provision which broadly align with other family leave.

Action: Consider whether a rule amendment is required.

Upcoming rules on identity verification and corporate filing

Changes under the Economic Crime and Corporate Transparency Act (ECCTA), intended to prevent the use of corporate entities for criminal purposes, are being brought in gradually. By autumn 2025, identity verification is expected to be a compulsory part of incorporating a new company and appointing new directors and Persons with Significant Control (PSCs); there will be a 12-month transition phase for existing directors and PSCs. Companies House has now launched a service allowing individuals to verify their identity voluntarily if they wish. From spring 2026, new restrictions on who can file documents at Companies House on behalf of companies are expected.

Action: Corporate trustees should keep a watching brief and begin identifying procedures which will need updating. Consider whether you wish to voluntarily verify identities ahead of mandatory requirements. Read more about the Economic Crime and Corporate Transparency Act 2023 here. 

Watch this space

• The forthcoming Pension Schemes Bill is expected before Parliament’s summer recess. It is due to cover measures including the automatic consolidation of deferred DC small pots and the introduction of a standardised Value for Money test for DC schemes. It will also introduce duties for trustees to offer decumulation options to members and will remove the need to apply to the County Court to enforce the recovery of an overpayment following a TPO decision.
• Following November’s Mansion House Speech, the government has published an interim report on its Pensions Investment Review, together with a consultation on new proposals for accelerating consolidation in the DC market. Key proposals are that master trusts and GPPs used for auto-enrolment should have a maximum number of defaults, and that these should operate at a minimum size. The government is also seeking views on the introduction of new duties for employers to specifically consider the value that is provided by the pension arrangements for their staff. A decision on whether to include these measures in the upcoming Pension Schemes Bill will be made following the consultation process. The Pensions Minister has announced that the final report on the Review will be published in the coming weeks.

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