The Pensions Minister also announced, during the third reading, that the Government intends to develop statutory guidance explaining what trustees of private, trust-based pension schemes must do to meet their fiduciary duties. The Government aims to provide more details on this over the next few months.

The announcement made in the 2025 Budget, that surplus payments to members over pension age may be permitted from April 2027, will require further legislation and is therefore not yet included in the Bill.

The Bill passed the House of Commons and was sent to be considered by the House of Lords, of which the second reading took place on the 18 December 2025. This involved general debate, but no further amendments have been announced. The Bill will now be scrutinised by the Committee in detail, which is scheduled to begin on 12 January 2026. 

Worryingly, the survey determined that awareness of the proposed duty was very poor amongst small and micro schemes. 87% of micro schemes (12 members) and 53% small schemes (12-99 members) were not aware of the duty. This fed through to a question asking if Schemes had considered moving to a master trust, which could help with this specifically and other duties. Only 12% of small and 4% of micro schemes had looked at this option or would be considering a move to master trust in future. In contrast, every master trust was aware of the proposed duty, as were over three-quarters (77%) of large and 76% of medium schemes.

These findings add further impetus to the move toward fewer, larger, better-governed schemes, with master trusts playing a central role. Smaller schemes face increasing pressure to improve in a number of areas, with guided retirement yet another area for them to comply with.

Action for trustees:

• Review and assess any existing decumulation options
• Based on that review develop default retirement income pathways to guide members into suitable decumulation options

Action for employers:

• Liaise with your pension provider or advisers to understand what decumulation options are available.

How we can help:

We can help Trustees review their options and ensure they have a suitable default pension benefit solutions in place for their members.

Driving better outcomes: What TPR’s modernisation means for you

In November 2025, Nausicaa Delfas, Chief Executive of TPR, set out a bold vision for a modern, proactive regulatory system that puts savers at the heart of decision-making. This wasn’t a compliance update, but rather a fundamental shift in expectations for trustees, sponsors, and providers alike.

Key takeaways from TPR’s speech

• Outcomes over box-ticking: Governance will continue to evolve to focus on whether savers achieve good retirement outcomes. Expect sharper scrutiny of investment strategies, risk management, and member communications.
• Value for money as a core metric: Schemes must evidence that members are getting real value, not just meeting minimum standards. This aligns with the government’s wider push on value-for-money frameworks for DC pensions.
• Data and digital first: Modernisation means greater use of data analytics and digital tools for real-time risk monitoring. Schemes should assess data quality and readiness for digital reporting now.
• Proactive intervention and collaboration: The regulator wants to act earlier to prevent harm, not just respond after issues arise. Expect closer collaboration between TPR, trustees, advisers, and providers to raise standards.
• Innovation and risk management: With new products, consolidation, and technology reshaping pensions, TPR expects robust governance frameworks to manage emerging risks. 
• Member-centric communications: Clear, timely, and engaging communication is no longer optional. TPR sees this as critical to building trust and helping members make informed decisions.

Modernisation will raise the bar for governance and transparency. Schemes that embrace digital, strengthen risk frameworks, and prioritise member outcomes will be well-placed in this new environment.

How we can help:

Barnett Waddingham can support with:

• Governance reviews and readiness assessments
• Digital and data strategy for pensions
• Member engagement and communication planning

TPR says member data is a strategic asset

On 18 November 2025, TPR published revised member data quality guidance following its market oversight report on data quality. 

The report emphasises that a core responsibility for trustees is to make sure data quality is well managed and it goes on to say that member data should be treated as a strategic asset rather than an operational detail or just to meet regulatory compliance. Excellent data quality helps to ensure efficient scheme management, informed decision-making, and accurate benefit delivery.

TPR acknowledges that significant progress has been made to improve data quality in preparation for pensions dashboards but some schemes still have more to do to get their member data in shape.

Julian Lyne, TPR’s Executive Director of Market Oversight, said: “Good data is the foundation of good governance and a trustee’s most important strategic asset. Trustees are accountable for ensuring member data is correct – no-one else. Maintaining its quality is an ongoing responsibility, because neglect can be costly and have real-world consequences for savers.”

Actions for trustees:

• Assess both common data (personal identifiers) and scheme-specific data (benefit details).
• Assess data quality at least annually (or more often for large/complex schemes).
• Use clear scoring methodology for completeness and accuracy.
• Create formal, time-bound plans with clear responsibilities and resources.
• Embed data quality in risk management and board oversight, avoiding overreliance on administrators.

The response outlined:

• details that legislative changes will be introduced via a statutory instrument, with the FCA’s authorisation gateway scheduled to open in March 2026 giving firms time to prepare (the framework is then expected to launch in April 2026); and 
• that targeted support will improve consumer outcomes by offering practical, tailored guidance, while maintaining robust protections.

On the same day, the FCA published their Policy Statement regarding targeted support, setting out near-final rules for the new regulatory framework, including:

• Firms must have a clear processes with strict definitions for consumer situations or segments (e.g. age or savings level) to prevent overly individualised profiling.
• Firms should use ready-made suggestions and actions for consumers.
• Support will need to be Consumer Duty compliant, with clear disclosures clarifying that it is not individual advice.
• Firms will need FCA approval to provide targeted support, which will be managed via a gateway.
• Firms should communicate to consumers outlining what targeted support is, its limits, and why the consumer falls into a certain situation or segment.
• Firms are now able to issue whole-of-market annuity brokerage directions without requiring a break before annuity sales.
• Support must be managed in line with joint guidance from the Financial Ombudsman Service and Information Commissioner's Office on complaint handling and marketing compliance. Complaints will still be handled under existing FCA rules.

Retirement CDC: Consultation 

Early December saw the close of the Department for Work and Pensions’ consultation on Retirement Collective Defined Contribution (R-CDC) schemes - a development that could reshape the way we think about retirement income for DC savers.

At Barnett Waddingham, we welcome the ambition behind this consultation: to broaden the range of options available to retirees. Our response was deliberately constructive, recognising the potential benefits of collective risk-sharing while sounding a note of caution. R-CDC could offer a compelling alternative for those seeking predictable income without the cost of guarantees. But innovation in pensions is never without complexity. If introduced too quickly or without the right safeguards, R-CDC risks unintended consequences that could undermine confidence in the wider system.

Key themes from our response

• Cautious Support for Innovation: Extending access to CDC is a positive step - but it should complement, not replace, ongoing improvements to DC retirement solutions.
• Investment Strategy Challenges: R-CDC is not whole-life CDC. With no regular contributions and a pensioner-only membership, investment strategies must:
  • Focus on stable, inflation-aware income
  • Manage liquidity and sequencing risk
  • Build resilience for market stress.  Robust stress testing will be essential.
• Scale and Sustainability: Early scale matters. Without it, schemes risk poor performance and loss of trust. Government may need to consider mechanisms - such as guided retirement defaults - to accelerate growth, while ensuring this does not disadvantage DC members.
• Member Protection and Complexity: Transfers without consent raise concerns. Safeguards should include:
  • clear, early communications; and
  • standardised disclosures on benefit variability and charges.
• Design Simplicity Over Complexity: While cohorting aims to address fairness, we believe a single-pool model with transparent annual adjustments offers a simpler, more sustainable solution.

Looking ahead

R-CDC has potential - but success depends on clarity, governance, and member understanding. This is not just about creating a new product; it’s about building trust in a new way of delivering retirement income. 

We will continue to engage with policymakers and industry stakeholders to ensure this potential next chapter delivers better outcomes for savers.

How we can help:

Please contact your Barnett Waddingham consultant if you would like to:

• Arrange a training session on how CDC schemes work in practice and how they differ from DB and DC
• Explore whether R-CDC could be an option for your scheme
• Receive a copy of our full consultation response

The Money and Pension Service MoneyView 2025

It is widely recognised that poor financial wellbeing significantly impacts the workplace through reduced productivity, increased absenteeism, and higher staff turnover. Employees struggling with money worries often experience heightened stress and anxiety, which directly affects their work performance and overall engagement.

On 5 November 2025, the Money and Pensions Service (MaPS) published its latest research as part of Talk Money Week, an annual campaign designed “to encourage people to #StartTheConversation about money and pensions”.

MoneyView2025 is the latest large-scale survey about the financial wellbeing of UK adults aged 18-65. In total, 12,534 people were interviewed between July and October 2024. 

Key findings at a glance

Financial resilience:

• 52% struggle to keep up, are falling behind, or have fallen behind with paying their bills
• 19% regularly use credit, overdrafts, or borrow for essentials
• 53% couldn’t manage three months’ expenses without borrowing
• 26% couldn’t afford a £300 unexpected bill

Retirement:

• 53% don’t feel they understand pensions well enough for retirement decisions
• 50% have no plan for future finances

Savings:

• 46% do not save regularly

Financial education and digital inclusion:

• 52% of all adults are not confident making decisions about financial products and services
• 18% of all adults do not use internet / mobile banking

Action for employers:

To support employees consider implementing a financial wellbeing strategy, which could include:

• Providing financial education and guidance workshops and webinars
• Introducing workplace savings schemes (e.g. workplace ISA)
• Partnering with debt advice organisations

In 2024, it is estimated £32bn of pensions contributions used salary sacrifice pension arrangements, with the value of contributions predominantly from higher and additional rate taxpayers.

As the new rules won’t come into force until April 2029 employers offering salary sacrifice for pension contributions don’t need to make immediate payroll or communication changes. 

Action for employers

For those currently using salary sacrifice:

• Review the potential future cost to their business and employees, and plan how to manage it, especially if employer NIC savings are shared with employees.  
• Where not already utilised consider introducing bonus exchange, although this will need careful planning and clear employee communication ahead of April 2029.

For those not currently using salary sacrifice:

• Consider introducing salary sacrifice for ongoing employee contributions and bonus exchange, although this will need careful planning and clear employee communication ahead of April 2029.

How we can help

• Contribution modelling to demonstrate the savings that could be achieved through salary/bonus sacrifice
• Communications support on the implementation of a new scheme and the on the forthcoming changes.
   

Active consultations affecting DC pensions

Trust-based pension schemes: Consultation aimed at trustees focussing on improving standards of pension scheme trusteeship, governance and administration. This consultation has proposals on increasing knowledge and understanding requirements with centrally set standards and accreditation for professionals and measures to improve the diversity of trust boards. The closing date for this consultation is 6 March 2026.

Extending the collective defined contribution (CDC) code of practice consultation: Consultation aimed at amending the existing CDC code which applies to single and connected employer CDC schemes (‘single-employer CDC schemes’) so that it will cover the authorisation and supervision of unconnected multiple employer schemes providing CDC benefits (‘multi-employer CDC schemes’). The closing date for this consultation is 13 February 2026.

The Value for Money Framework: Response to consultation, further consultation and discussion paper - Consultation aimed at refining the FCA’s Value for Money Framework on how workplace pension arrangements are assessed. It proposes streamlined metrics, a market comparator group, and a four point rating system to help identify top performing schemes. The closing date for this consultation is 8 March 2026.

Forthcoming events:

• Webinar: Britain’s Got Talent: understand people risks and improve retention – Thursday 26 February
• Training: DB trustee online training sessions – Tuesday 24 - Thursday 26 February
• Training: DC pensions training – Wednesday 4 - Thursday 5 March