March 2026

The Pensions Brief: March 2026

Auteurs:

Data (Use and Access) Act 2025 – Handling Complaints

The requirement under the Data (Use and Access) Act 2025 (the “Act”) for organisations to have a process in place for handling data protection complaints will come into force on 19 June 2026. Under the Act, organisations must:

Give people a way of making data protection complaints;
Acknowledge receipt of complaints within 30 days;
Without undue delay, take appropriate steps to respond to complaints, including making appropriate enquiries, while keeping people informed; and
Without undue delay, tell people the outcome of their complaint.

The Information Commissioner's Office (ICO) has published guidance on complying with the new requirement. For more information on the new requirement, please see our February Legal Update. The majority of the remaining provisions of the Act (which do not impose any new obligations on trustees) came into force on 5 February 2026.

In addition, the ICO has updated its guidance on the following topics to reflect the Act:

Action
Trustees and administrators should ensure that a complaints-handling process is put in place by 19 June 2026.

Pensions Dashboards – Q&As

The Pension Dashboards Programme has published FAQs on the dashboards reporting standards. The FAQs cover:

What the reporting standards are and who is responsible for adhering to them;
The proposed changes to the reporting standards;
The consultation arrangements for the proposed revised standards; and
Additional guidance on reporting.

In addition, the Pensions Administration Standards Association (“PASA”) has published Q&As from its recent webinar on its dashboards data matching guidance and toolkit.

Action
No action required, but trustees and administrators of schemes that are subject to the dashboards requirements may find the two sets of Q&As helpful.

Digital Transformation – Implementation

PASA has published the last in its three-part series of guidance on delivering effective digital transformation. The guidance focuses on how to translate strategy and planning into delivery, embedding member engagement, change management and iterative improvement into day-to-day operations.

Action
No action required

Issues Affecting DB Schemes

Pension Protection Fund – 2026/27 Levy

The Pension Protection Fund has confirmed that it will set a zero levy for the 2026/27 levy year for conventional DB schemes. However, it will continue to charge a levy for alternative covenant schemes (e.g., DB superfunds).

Action
No action required.

Mayer Brown News

Updates

At the end of January, Duncan Watson attended Mayer Brown’s two-day Private Investment Funds Academy in our Salt Lake City office. Members of the firm’s Global Fund Formation & Investment Management group attended from our London, New York, Chicago, and Salt Lake City offices, and participated in multiple training sessions, including on Fund Exits (including Secondary Transactions) and on Waterfalls and Management Fees.
In February, Duncan Watson gave a talk to around 40 students from the Aberdeen University Law Society. He talked about his career, from graduating from the University’s law school, through training and practising in Edinburgh, and then moving to London and what it is like working in a US law firm in London.