The Pensions Brief: September 2026

Issues Affecting All Schemes

Inheritance Tax: Further Technical Note

HM Revenue & Customs (HMRC) has published a further technical note for schemes on how the new inheritance tax (IHT) regime for death benefits paid from registered pension schemes will work in practice. The note covers topics including:

• Information-sharing;
• Withholding and payment notices; and
• The interaction of IHT and income tax on death benefits.

It also includes draft guidance on verifying the identity of personal representatives and draft template withholding and payment notices.

Action
Trustees and administrators should review the note, and factor its contents into their preparations for the April 2027 introduction of the new IHT regime.

Normal Minimum Pension Age: Consultation on Transitional Provisions

HMRC is consulting on draft legislation setting out transitional provisions that will apply in relation to the 2028 increase in normal minimum pension age. The provisions are designed to ensure that, where individuals aged 55 or 56 have become entitled to, or taken steps to access, certain benefits prior to 6 April 2028, payment of those benefits after that date but prior to the individual reaching age 57 are not treated as unauthorised payments. The consultation closes on 28 September 2026.

Action
No action required.

Pensions Dashboards: Guidance

The Pensions Dashboards Programme (PDP) has published guidance for schemes on how to report manually to the Money and Pensions Service prior to the commencement of daily reporting via API.

The PDP has also published a blog post on the importance of schemes maintaining their connection to the dashboards ecosystem and what schemes need to do to remain connected, meet their obligations and ensure a reliable dashboards user experience.

In addition, the Pensions Administration Standards Association (PASA) has published:

• Guidance to help schemes respond clearly and consistently to member enquiries about dashboards. The guidance provides a practical set of FAQs and suggested responses. PASA expects the guidance to be treated as an interim resource and adapted by schemes to reflect their own processes and the latest available information.
• Guidance to help schemes understand how member behaviour changes once pensions dashboards become available. The guidance outlines a range of reporting measures which schemes may wish to consider, looks at whether this information is likely to be available through existing reporting, and suggests additional data which could provide further insight.

Action
No action required, but trustees and administrators of schemes that are subject to the dashboards requirements may find the guidance helpful.

Economic Crime and Corporate Transparency Act 2023: Updated Implementation Timetable

Companies House has updated its timetable for implementation of the Economic Crime and Corporate Transparency Act 2023 to postpone implementation of the following reforms:

• The requirement for identity verification of any person filing a document.
• The requirement for third-party agents filing on behalf of companies to be registered as an authorised corporate services provider.

These reforms will come into force no earlier than November 2027 and Companies House will give at least six months’ notice.

Action
No action required.

Professional Advice: Reliance

The Upper Tribunal has decided that it was not reasonable for two scheme administrators to rely on advice that they did not need to comply with information notices from HMRC because the schemes in question had been wound up. The Tribunal held that legislation and case law requires that, in relying on advice, an individual must exercise their independent judgement and take reasonable care. The individuals had failed to do so as they relied on short advice emails that lacked detail and clarity and had not asked to see the correspondence with HMRC to check that the information being sent to HMRC on their behalf was correct.

Action
No action required.

Issues Affecting DB Schemes

Pension Increases: Interpretation of Scheme Rules

The High Court has considered the interpretation of a scheme’s pension increase rule. The rule provided for inflation-based increases capped at 5%. However, it also allowed the trustees to pay the excess above 5% if, having consulted the actuary, they considered this could be done without requiring an increase in the employer’s ordinary annual contributions.

The court held that:

• The trustees were required to consider whether payment of the excess would necessitate any future increase in employer contributions, whether an immediate increase and/or an increase at the next valuation; and
• The trustees could take into account all reasonably foreseeable future events, but the test was whether there was material uncertainty about whether an increase in employer contributions would be required, rather than just whether there was a possibility that an increase would be required.

Action
No action required.

Benefit Augmentations: Form of Payment

The Pensions Ombudsman (TPO) has rejected a complaint by a member that a benefit augmentation had been paid to him in the form of additional pension rather than as a lump sum. TPO concluded that the trustee had followed a thorough and considered decision-making process with which he could find no fault. He also decided that while the scheme’s trust deed and rules did not require the trustee to consider the tax implications for members of being paid a lump sum, it was reasonable for the trustee to include this as one of the factors it considered in reaching its decision.

Action
No action required.

Ill-Health Early Retirement Pensions: Review

TPO has rejected a member’s complaint that a trustee’s decision to increase his ill-health early retirement pension from Tier 3 to Tier 2 at its 18-month mandatory review meant that the original decision to award a Tier 3 pension was incorrect. TPO decided that the original decision had been reached following a proper decision-making process. The decision to increase the pension to Tier 2 just meant that the expected course of the condition/symptoms based on the available treatments was not borne out. The views provided by medical experts are made on the balance of probability and there will therefore always be an element of uncertainty about prognosis. An assessment as to the propriety of the decision-making process should not apply the benefit of hindsight.

Action
No action required.

Issues Affecting DC Schemes

Value for Money: Guidance on New Framework

The Pensions Regulator (TPR) has published:

• An overview of the new VFM framework which provides practical information for trustees on the latest proposals for the framework and how they can start preparing to comply.
• A technical overview of the proposed digital solution for the framework which provides practical information on the solution and how trustees can start preparing for data submission.

TPR has also updated its Pension Schemes Act 2026 webpage to include links to the two overviews and updated information on when further VFM communications are planned.

Action
No action required, but trustees of DC schemes may find the guidance helpful.

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