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UK Pensions
Tracker
Key developments: October to December 2026
Pension Schemes Act 2026
Inheritance Tax
GMP
Case law
Topic
Expected developments
Autumn 2026: HMRC Technical Note 3
Autumn/Winter 2026/27: draft guidance and additional regulations
29 October 2026: DWP consultations close on GMP fixed-rate revaluation and GMP conversion regulations
15 December 2026: DWP consultation on draft regulations closes.
Retirement CDC schemes
Verity Trustees case: judgment awaited
DC Scale & Consolidation
Reforms aimed at creating larger pension arrangements and accelerating consolidation across the DC market
April-June 2027: report on effects of consolidation on pension schemes
October-December 2027: DWP consultation on regulations
January-March 2028: TPR and FCA consultations on code and guidance
October-December 2028: regulations laid
2029: applications and assessment periods commence
January-March 2029: Fragmentation Review begins and requirements for new default arrangements published
January-March 2030: Fragmentation Review report
April-June 2030: Minimum scale requirements take effect and transition pathway commences
End of 2035: transition pathway ends. All master trust and group personal pensions to have at least £25 billion in assets
Topic
Pension Schemes Act 2026
Progress to date
Value for Money Framework
New framework to assess pension arrangements beyond cost alone
July-September 2026: DWP/FCA consultation on draft regulations and FCA rules completed. Responses are being analyzed
11 August 2026: TPR published VfM overview for trust-based DC schemes
CDC schemes are currently excluded from VfM but are likely to be brought into scope in future
July-September 2026: FCA/TPR consultation CP26/25 on DWP draft regulations and FCA rules closes 1 September 2026.
July-September 2026: TPR additional guidance
January-March 2027: DWP regulations in force and FCA policy statement published
January-March 2027: Consultation on TPR code
January-March 2028: TPR code in force, and schemes submit first VfM data to TPR/FCA as appropriate
October-December 2028: first assessment reports and relevant data published
January-March 2029: schemes submit second year VfM data
October-December 2029: VfM second year assessment reports and data published
22 December 2026: DWP policy consultation and FCA discussion paper closes
July-September 2027: DWP consultation on regulations and FCA consultation on rules
April-June 2028: TPR guidance published for consultation
July-September 2028: regulations made, FCA policy statement published and FRC standards published in relation to the design of decumulation options
July-September 2029: Commencement for master trusts and FCA regulated workplace schemes
July-September 2030: Commencement for single employer trusts and schemes with retirement CDC as the default option
13 July 2026: DWP published its Guided Retirement guiding principles
3 November 2026: DWP, FCA and TPR published the Guided Retirement policy consultation, which also serves as the FCA discussion paper
Guided Retirement Solutions
Requirement for DC workplace schemes to support members transitioning from pensions saving into retirement by providing default decumulation solutions
15 September 2026: DWP consultation opened and closes on 17 November 2026
Small Pots Consolidation
Automatic consolidation model to reduce fragmented pension savings
October 2026-January 2027: DWP consultation response and TPR consultation on further guidance
6 April 2027: expected commencement for surplus return legislation, including tax changes
10 June to 2 September 2026: DWP consultation on draft surplus regulations completed; Government response awaited
13 July to 7 September 2026: HMRC technical consultation on authorised surplus payments to members completed
DB Surplus
Reforms to facilitate the return of surplus from ongoing DB schemes
DB Superfunds
A permanent statutory framework for the authorisation and supervision of DB superfunds
January-April 2027: DWP consultation on draft regulations
January-October 2028: TPR consultation on code
January-October 2028: TPR Code of Practice and DWP regulations to come into force
October-December 2026: HMT regulations laid
January-March 2027: FCA consultation on rules
July-September 2027: FCA policy statement
March 2028: contractual override enabled
Contractual override
A statutory mechanism for contract-based arrangements to enable transfers into better value arrangements without individual member consent
27 January 2027: DWP consultation on draft guidance on pension trustees – investment and fiduciary duties closes
Fiduciary duty and investment decision-making
Provides greater clarity on trustees' fiduciary duties when making investment decisions
Effective from Royal Assent, subject to 'sunset' provisions from 2032 and will be fully repealed by 2035
Mandation reserve powers
A reserve power allowing Government to mandate minimum investment allocations for qualifying DC pension schemes in prescribed assets
Other matters
CDC for unconnected employers
Expansion of the CDC regime to enable multi-employer CDC schemes for unconnected employers
Retirement CDC schemes
Further expansion of the CDC regime to enable retirement-only CDC arrangements
January to June 2027: first scheme authorisations expected
Topic
Summary
31 July 2026: enabling regulations and the final CDC Code of Practice came into force; applications for authorisation opened
15 December 2026: DWP consultation on the draft Retirement Collective Money Purchase Scheme regulations closes.
January to June 2027: DWP consultation on retirement-only CDC regulations
July to December 2027: TPR consultation on changes to the CDC Code
July to December 2028: regulations and code come into force and applications for authorisation open
January to June 2029: first retirement-only CDC authorisations
Autumn 2026: HMRC Technical Note 3 expected
Autumn/Winter 2026/27: draft guidance and additional regulations expected.
Spring 2027: final guidance and supporting materials expected
6 April 2027: IHT changes commence
15 July 2026: final information-sharing regulations laid; in force from 6 April 2027
27 August 2026: HMRC Technical Note 2 published
From 6 April 2027, most unused pension funds and pension death benefits will fall within a deceased member's estate for IHT purposes under the Finance Act 2026
Progress to date
Next steps and timelines
HMRC stakeholder engagement and further guidance expected before 6 April 2029
Secondary legislation will set out the detailed operation of the £2,000 cap
Salary sacrifice
The National Insurance Contributions (Employer Pensions Contributions) Act 2026 introduces NICs on salary sacrifice pension contributions exceeding £2,000 per year, effective from 6 April 2029
Inheritance tax
Spring 2027: final report planned
19 May 2026: Interim report published
Pensions Commission
The Government has established a new independent Pensions Commission to examine long-term pensions adequacy, retirement outcomes and future policy priorities
31 October 2026: Mandatory connection deadline
Dashboards
Schemes continue preparing for mandatory connection to the pensions dashboards ecosystem, with increasing focus on data quality, operational resilience and connection readiness
Verity Trustees case: Judgment awaited
The statutory remediation provisions are in force and TPR guidance has been published
Case law
29 October 2026: closure of consultations on the fixed revaluation rate and conversion
DWP is consulting on the fixed revaluation rate for GMPs and on draft regulations intended to clarify the statutory GMP conversion process
GMPs
Virgin Media fix - The Pension Schemes Act 2026 introduced a statutory mechanism allowing schemes to remedy certain historic amendments affected by the Virgin Media judgment where actuarial confirmation was absent
3 November 2026: DWP published response to the earlier policy consultation and consulted on draft regulations
April-June 2027: Government response published in relation to DWP policy consultation and consultation on draft regulations
October-December 2027: Second DWP policy consultation on further consolidation considerations
January-March 2028: DWP response to consultation on regulations and draft regulations laid
January-March 2028: FCA policy statement published
April-June 2028: Government response published in relation to second DWP policy consultation and consultation on further draft regulations
January-March 2029: Second set of draft regulations laid
April-June 2030: Consolidation begins
Guided Retirement Solutions: DWP policy consultation and FCA discussion paper published on 3 November 2026. Consultation closes on 22 December 2026
DB Surplus: October 2026-January 2027: Government response on DWP consultation and TPR consultation on further guidance
Small pots: DWP consultation closes on 17 November 2026
Contractual override: October-December 2026: HMT regulations laid
5 November 2026: DWP consultation on draft guidance on pension trustees - investment and fiduciary duties opened, closes 27 January 2027
Last updated 6th November, 2026
Summary
Next steps and timelines
Carolyn Saunders Partner
D +44 20 7320 6585
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Eleanor Hart
Partner
D +44 20 7246 7166
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Key contacts
Ed Hunnisett Partner
D +44 20 7246 7470
Email