HL UK Pensions Digest 12 March 2026

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A bite-sized summary of recent UK pension news

Pension Schemes Bill: further amendments

  • Government amendments concerning investment duties; pre-97 increases on Pension Protection Fund (PPF) compensation; and guided retirement;

Master trusts: scale and consolidation

  • More detail from the DWP and the Pensions Regulator (TPR) on pathways for reaching the scale requirements in the Pension Schemes Bill;

The Financial Conduct Authority: pensions priorities for the year ahead

  • The Financial Conduct Authority (FCA) has published its regulatory priorities for pensions for 2026.

Pension Schemes Bill

The Pension Schemes Bill completed Committee stage in the House of Lords on 23 February 2026 and is due to start Report stage from 16 March 2026. A considerable number of amendments have been tabled for consideration on Report.

Points to note from amendments tabled by the government include the following.

Guided retirement

The definition of “eligible member” will be amended to ensure that default retirement solutions must be designed and made available to deferred members, in addition to active and pensioner members:

Indexation of pre-97 Pension Protection Fund (PPF) compensation

The Bill will require future indexation of pre-97 PPF compensation where the original scheme rules provided for pension increases. If the original scheme only provided increases to guaranteed minimum pensions (GMPs), more limited increases will apply to members’ pre-97 PPF compensation.

Where a scheme equalised for the effect of GMPs before entering the PPF, GMP equalisation uplifts may have been granted to disadvantaged members. These uplifts are not, in legal terms, part of the GMP.

Government amendments to the Bill will ensure that, where a scheme provided increases only to GMPs and GMP equalisation uplifts, the more limited increases will apply to pre-97 compensation.

Statutory guidance on investments

A new clause in the Pensions Act 1995 will oblige the Secretary of State to issue guidance on the detailed requirements for a statement of investment principles and for choosing investments. Trustees of occupational pension schemes, and any fund manager exercising investment powers on their behalf, must have regard to the guidance.

The guidance:

  • Must explain such aspects of those requirements as the Secretary of State considers appropriate;
  • May explain the meaning of any relevant expression (for example, “financially material considerations”, “environmental, social and governance considerations”, and “best interests of members”); and
  • May include examples to demonstrate how the law applies to particular scenarios.

The first guidance must be published within 12 months of the new clause coming into force.

The Pensions Minister, Torsten Bell, had previously committed to issuing statutory guidance on trustees’ investment duties and has set up a working group to consider the issues.

Return to Contents.

Master Trusts: scale and consolidation

The DWP has issued a paper on the requirement in the Pension Schemes Bill for defined contribution (DC) multi-employer schemes to operate a main scale default arrangement (MSDA) with at least £25 billion in assets from 2030. The Bill also provides for a transition pathway for schemes with at least £10 billion of assets and which are expected to reach £25 billion by 2035, plus a separate pathway for new entrants.

Multi-employer schemes within the remit of the new requirements, or wishing to use the transition or new entrant pathways, must be approved by the Pensions Regulator (TPR) (for Master Trusts) or by the Financial Conduct Authority (FCA) (for group personal pensions).

The paper sets out the government’s intentions ahead of detailed consultation on draft regulations, including its expectation that schemes intending to use the transition pathway should be developing a clear credible growth plan for achieving scale.

Alongside the DWP paper, TPR issued a press release and a statement explaining what it would expect to be included in a scheme’s credible growth plan.

For more details on the scale requirements please see our Digest of 6 February 2026.

Return to Contents.

The Financial Conduct Authority publishes its pensions priorities for the year ahead

On 10 March, the Financial Conduct Authority (FCA) published a report outlining its priority areas of focus for firms in the pensions sector for the next year. It follows the publication of similar reports for the insurance and consumer investment sectors.

Purpose

The report replaces the FCA's portfolio letters, and will be published annually. It is intended to help firms better understand the FCA's expectations, strengthen compliance, support innovation, and ultimately deliver improved outcomes for consumers.

The priorities outlined in the report will apply to firms regulated by the FCA, primarily centred around the contract-based defined contribution (DC) market, such as life insurers, self-invested personal pension (SIPP) operators and asset managers.

The report contains an indicative timeline of key dates for 2026, which lists the FCA's upcoming publications and consultations in relation to each priority area.

The FCA's pensions priorities

The report sets out the FCA's four key priority areas for the pensions sector for the next year, alongside the FCA's own action points during that period:

Ensuring well-run schemes that provide value for money to savers

The FCA notes that it will finalise the value for money (VfM) framework this year, giving firms time to implement system changes before the 2028 launch. The FCA expects firms to provide feedback, prepare for implementation and address schemes unlikely to be providing value (for example, by asset reallocation or member transfer).

  • Encouraging effective support for consumers

The FCA expects firms to consider the support consumers might need to better understand and make decisions as the market changes, whether due to the Pension Schemes Bill, wider events, market volatility or the introduction of dashboards.

  • Supporting growth and innovation

The FCA wants to remove any unnecessary barriers to investing in private markets. It expects firms to review their approach to asset allocation, including opportunities for investment in private assets where this is judged to be in the best interests of savers. Where firms are investing in a broader range of asset classes, the FCA advises them to consider how their control framework should evolve.

  • Modernising pensions and long-term savings

The report emphasises the need for firms to engage with the FCA to discuss longstanding issues (such as aging technology and difficulties in contacting consumers) that may hinder improved consumer outcomes; and to give feedback/test ideas as the FCA develops solutions.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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