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.
New corporate identity verification and filing requirements from 18 November 2025 NEW
From 18 November 2025, identity verification will be compulsory for new directors and Persons with Significant Control (PSCs) of companies; existing directors and PSCs will need to verify their identity with their next annual confirmation statement (read more). There will also be changes to company register requirements (read more).
Action: The exact scope of the changes remains unclear in some aspects; contact your usual AOS adviser for further information.
Draft legislation on pensions and IHT
Unused pension savings will be brought into the scope of Inheritance Tax (IHT) from April 6, 2027, although death in service lump sums will fall outside the scope of IHT. For more details, see ‘Have your say’ below.
Action: The exact scope of the changes remains unclear in some aspects; contact your usual A&O Shearman adviser for further information.
Pension Schemes Bill 2025 published
The Pension Schemes Bill has been published, containing a raft of changes to the DC pensions landscape, including:
- a value for money framework;
- requirements for master trusts and GPPs to have a default fund with a minimum level of assets under management and potentially a prescribed level of investment in ‘productive assets’;
- a framework for consolidation of small, dormant pots; and
- requirements for schemes to provide members with a guided retirement product.
Regulations will set out the details of the proposals. Read more.
A roadmap published alongside the Bill sets out a guideline of timings for the various changes. The aim is that the Bill will be passed at the start of 2026.
Action: Keep a watching brief as the Bill progresses and regulations are published. Arrange training on the aspects that affect your scheme.
Have your say
- The Government has published a consultation response, policy paper and draft legislation on bringing pensions into the scope of Inheritance Tax (IHT) from April 6, 2027. Key points to note are (a) death in service benefits will fall outside the scope of IHT; (b) personal representatives (not pension schemes) will be responsible for reporting and paying any IHT due; and (c) schemes will be subject to new duties, including a ‘scheme pays’- style mechanism for settling IHT bills. The draft regulations are open for consultation until September 15, 2015.
- The Government has launched a call for evidence seeking views on the detail of the Pension Schemes Bill by September 2, 2025.
Pensions Academy Online: Tuesday 7 and Thursday 9 October 2025
Our next Pensions Academy Online webinars will take place on Tuesday 7 and Thursday 9 October 2025. Each webinar begins at 9.30am and will last approximately one hour. If you would like to attend, please register here.
We will be covering:
- Legal update – Tuesday 7 October 2025: we’ll round up all the latest developments and outline what’s on the pensions horizon.
- Pensions 2030 and beyond: preparing now for the future landscape – Thursday 9 October 2025: we’re facing significant change across the UK pensions landscape and more could be coming. We’ll look at the big
picture from the perspectives of trustees, employers and members, to help you plot a route from here to there.
Watch this space
- Regulations allowing multiple unconnected employers to establish a CDC scheme are expected in the autumn.
- The Government intends to consult on trustee accreditation and governance later this year.
- The Data (Use and Access) Act (DUA Act), which makes amendments to the UK General Data Protection Regulation and Data Protection Act 2018, has received Royal Assent. Changes include helpful tweaks to deadlines for responding to data subject access requests and new requirements around handling data protection complaints. Many of the changes need regulations before coming into force.
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