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PENSION ADMINISTRATION TECHNICAL HELP
PATHways 180
Highlighting pensions news and legislation that has
particular relevance to what we do in pension administration
In this edition of PATHways, we cover:
- HMRC newsletter 177
- Legislation update
- TPR publishes guide to help trustees with VfM consultation
- PPF answers FAQs on pre-97 indexation
- PDP news
- PASA guidance on navigating buy-in and superfund transitions
Bhavna Baines contributed to the writing of this newsletter.
Legislation update
Draft GMP increase order 2026
The draft Guaranteed Minimum Pensions Increase Order 2026 has been laid before Parliament. This specifies that the rate by which post 5 April 1988 GMP’s must be increased from 6 April 2026 is 3% (the increase permitted under legislation, being the lower of the increase in the general level of prices in the period under review and 3%).
Transfer regulations – targeted support
The Financial Services and Markets Act 2000 (Regulated Activities) (Providing Targeted Support) (Amendment) Order 2026 was laid on 30 January 2026.
While this Order largely relates to enabling the Financial Conduct Authority (FCA) establish the targeted support framework and the FCA regulated activity that will be required, it also includes a consequential amendment to the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021 (and NI equivalent).
It amends the definition of ‘a regulated activity’ in the conditions for transfer regulations with effect from 6 April 2026, to include providing targeted support. This relates to the red flag where there is reason to believe that the member has been in contact with someone who agreed to or who has carried out prescribed regulated activities without the appropriate regulatory permissions from the FCA.
HMRC newsletter 177
HM Revenue & Customs (HMRC) published its Pensions schemes newsletter 177 for January 2026. This includes:
- Actions required for non-UK resident pension scheme administrators before 6 April 2026, such as removal from an ‘open’ status scheme or de-enrolling from the managing pension schemes service, as necessary.
- An invitation to participate in user research around the design of a new digital service that allows administrators to report inheritance tax payment notice details.
TPR publishes guide to help trustees with VfM consultation
The Pensions Regulator (TPR) has published an Overview for trust-based DC schemes - a guide to help trustees of such schemes understand and engage with the proposals outlined in its recent joint Value for Money (VfM) consultation. The consultation launched jointly with the FCA and the Department for Work and Pensions (DWP), sets out proposals for how VfM may be designed to work for both DC trust and contract based schemes.
In a blog, TPR says the guide is designed to help trustees understand the proposals in the consultation and engage with them, including those who have not engaged with the VfM framework before. The blog urges trustees of DC trust-based schemes to read the consultation and share feedback with TPR by 8 March 2026.
PPF answers FAQs on pre-97 indexation
The Government amended the Pension Schemes Bill in early December 2025 to include a provision that would enable the Pension Protection Fund (PPF) to pay pre-97 indexation for members of schemes which provided mandatory or statutory increases. The PPF has now published answers to their most frequently asked questions (FAQs) by members and other stakeholders on pre-97 indexation whilst the Bill proceeds through the remaining stages in Parliament.
PASA new and updated guidance
The Pensions Administration Standards Association (PASA) has published new and updated guidance during June 2024 in several of the areas its working groups cover.
Data Presence vs Accuracy
The PASA Data Working Group continues to produce content regularly and has published new guidance on ‘Data Presence vs Accuracy’. The main part of the guidance focuses on what trustees can do to improve data accuracy, suggesting trustees conduct an audit of data quality to identify potential issues in their data and areas of weakness, and on reviewing the data accuracy, carry out data remediation work as necessary. The guidance also suggests that consideration is given to ongoing monitoring on a periodic basis to help ‘future proof’ data accuracy.
Master trust transitions guidance
The PASA Master Trust Working Group has published updated guidance on master trust transitions following on from the original version issued in November 2019.
The updated guidance accounts for developments in the master trust space in the intervening years and is designed for situations involving transitions of savers to and from master trusts, focusing on the two most common scenarios:
- master trust to master trust; and
- single employer trust to master trust.
As well as industry developments, other topics covered include transition planning and suggested project governance, and communications.
PDP news
Updated reporting standards for consultation
The Pensions Dashboards Programme (PDP) has published for consultation an updated draft version 2.1 of the reporting standards for pension providers and schemes in scope for pensions dashboards. The reporting standards set out requirements for generating and recording operational information relating to dashboards and reporting it to the Money and Pensions Service (MaPS).
The consultation is open until 25 March 2026, with a proposed implementation date of 30 November 2026.
Proposed launch of private sector dashboards working group
PDP has requested industry feedback on a proposal to launch a private sector dashboards working group to extend industry collaboration and support delivery of private sector dashboards. While PDP’s current focus remains on the successful implementation of the MoneyHelper pensions dashboard, they inform that they remain committed to ensuring that private sector dashboards operated by other organisations are also delivered. The request for feedback closes on 10 February 2026, after which it will consider responses and provide a summary.
PASA guidance on navigating buy-in and superfund transitions
The Pensions Administration Standards Association (PASA) has published guidance to help trustees, administrators and advisers navigate buy-in and superfund transactions. The guidance, produced by PASA’s De-Risking Journey Management Working Group, focuses on the areas where schemes most often encounter friction, including: data integrity, rule alignment, member communication, deferred member complexity, risk management and resourcing.
PASA informs that the guidance highlights the critical role administration plays before, during and after transition in ensuring smooth delivery, regulatory compliance and positive member outcomes.
DWP – combining small pension pots
The Department for Work and Pensions (DWP) announced on 24 April 2025 plans to bring eligible small pension pots together under reforms to be included in the Pension Schemes Bill, as part of the Government’s Plan for Change. It follows the findings of the work conducted by the Small Pots Delivery Group aimed at supporting the design and implementation of the new small pots multiple consolidator scheme approach, The aim of the initiative is to:
- automatically combine the number of eligible small pots of £1000 or less into one pension scheme that is certified as delivering good value to savers. Individuals will retain the right to choose their own consolidator scheme or opt out;
- help workers keep track of their pensions and get a better rate of return on these retirement savings by reducing the number of flat rate charges paid from their multiple small funds; and
- save businesses millions in unnecessary costs involved with administering an increasing number of small funds, as a result of Automatic Enrolment.
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