Pensions: Joint DB & 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.

Clearing exemption to continue

The government has confirmed that the exemption preventing pension schemes from having to comply with clearing requirements for over-the-counter derivatives will continue indefinitely (it was scheduled to expire on June 18, 2025). Draft regulations making the necessary legislative changes have been published. This relates to the UK clearing exemption only; the similar EU exemption for European pension scheme arrangements has already ended.

Action: Stand down any changes planned based on the June 18 deadline.

Accessing DB surpluses: new rules expected

The government has announced that it will change the rules on accessing surpluses in DB schemes, to allow payments with the agreement of trustees and employers. Further details will be published in spring.

Action: Keep a watching brief, especially if your scheme has a surplus; employers may want to utilise the new rules and trustees will need to be prepared to navigate this.

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 on 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, the introduction of a standardised Value for Money test for DC schemes and the framework for commercial DB consolidators (superfunds). It will also introduce duties for trustees to offer decumulation options to members and remove the need for pension schemes 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 published an interim report on its Pensions Investment Review, with a consultation on proposals for accelerating consolidation in the DC market. The key proposal is that master trusts and GPPs used for auto-enrolment should have a maximum number of defaults of a minimum size. The government is also seeking views on new duties for employers to consider the value provided by pension arrangements. These measures may be included in the upcoming Pension Schemes Bill. The Pensions Minister has announced that the final report on the Review will be published in the coming weeks.
• There is currently no date for revised regulations on changes to the notifiable events regime.

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