Welcome to our monthly update on current legal issues for trustees of DC pension schemes, designed to help you stay up to date with key developments between trustee meetings, and to support the legal update item on your next trustee agenda. We have a separate update for DB/hybrid schemes.

Dashboards update UPDATED

Regulations have been laid before Parliament setting 31 October 2026 as the new dashboards connection deadline for all schemes. A staging timeline for connection will be set out in guidance, rather than legislation (read more).

The Pensions Regulator (TPR) has updated its initial dashboards guidance to reflect the revised connection timetable (read more) and has published a blog post encouraging schemes to focus on data readiness, warning of possible industry capacity issues (read more).

PASA has published guidance on answering member queries (read more), data matching (read more) and providing value data to pensions dashboards (read more).

An Act preventing trustees from using pension scheme assets to indemnify themselves against penalties imposed by TPR for breach of the pensions dashboards requirements has received royal assent (read more). This is in line with existing provisions in relation to other penalties.

ACTION: Continue preparation for pensions dashboards, in line with the guidance. Seek advice on what liability protections are available to trustees and ways to mitigate risk.

TPR blog post on protecting DC savers from economic volatility NEW

TPR has published a blog post on supporting DC savers through the current economic environment (read more). It focuses on steps to take in relation to those closest to retirement with the least time to make up investment losses, including reviewing the default strategy and member communications. In relation to younger savers, TPR suggests schemes may want to provide additional supporting materials alongside annual benefit statements, to help savers understand the context of the figures being provided to them.

ACTION: read the blog post and consider whether any changes are needed to support your DC members.

Climate/ESG reporting

TPR has published a review of schemes’ annual climate reports, identifying common areas of improvement and points of good practice (read more). TPR expects schemes to take these observations into account when drafting reports. It has also announced initiatives checking trustee compliance with climate and environmental, social and governance (ESG) requirements (read more here and here).

ACTION: Take TPR’s report into account when preparing your scheme’s climate reporting.

Watch this space

• The government has consulted on changes to the notifiable events regime. There is currently no revised date for the delayed regulations (read more).
• TPR has consulted on its proposed single code of practice (to be known as the General Code): watch our webinar on the proposals and read TPR’s interim response. Publication of the revised version of the code is expected soon.