Issues affecting all schemes
Company directors – identity verification requirements
Companies House has announced that the identity verification requirements under the Economic Crime and Corporate Transparency Act 2023 (the Act) will come into force on 18 November 2025. From that date:
- All new company directors and persons with significant control (PSCs) will be required to verify their identity within 14 days of their appointment/becoming a PSC.
- Existing company directors will be required to verify their identity when the company files its first annual confirmation statement following 18 November 2025.
- Existing PSCs will be required to verify their identity by an appointed date within the 12 months following 18 November 2025. The date will depend on whether the PSC is also a director of the company.
Directors and PSCs can verify their identity voluntarily before 18 November 2025. Companies House has also updated its guidance on when and how individuals can verify their identity.
In addition, changes to the records that UK companies are required to maintain and to the information that UK companies are required to file at Companies House will come into force on 18 November 2025. These include replacement of the requirement to maintain registers of directors, directors’ residential addresses, secretaries and PSCs with a requirement to notify certain information about directors, secretaries and PSCs, and any changes to that information, to Companies House.
For more information on the changes being introduced by the Act, please see our April 2025 legal update.
Action Trustee companies should speak to their company secretarial services provider (or whoever normally carries out their company filings) to confirm that they are aware of the changes and that steps will be taken to ensure compliance by the trustee company and its directors with the new requirements by the relevant deadline.
Death benefits – revised inheritance tax proposals
HMRC has responded to its consultation on proposals to charge inheritance tax (IHT) on most death benefits from 6 April 2027. Two key changes have been made to the proposals:
- Personal representatives (PRs) rather than schemes will now be responsible for reporting and paying any IHT payable on death benefits.
- Death in service benefits payable from registered pension schemes, whether discretionary or non-discretionary, will not now form part of the member’s estate for IHT purposes.
HMRC is now consulting on draft Finance Bill clauses making the necessary legislative changes. The consultation closes on 15 September 2025. HMRC will also consult at a later date on amendments to the provision of information legislation to reflect the new information sharing obligations that will be imposed on PRs and schemes.
For more information, please see our legal update.
Action Trustees and administrators should monitor publication of the consultation on the new provision of information requirements.
Pensions dashboards – new and updated guidance
The Pensions Dashboards Programme (PDP) has published guidance on voluntary connection to the dashboards ecosystem by schemes that have less than 100 relevant members. The guidance covers eligibility for voluntary connection and sets out the process for applying to connect and for connecting if permission is granted. Schemes can provide feedback on the process and register interest in connecting voluntarily. The PDP has also published FAQs on voluntary connection and a blog post on what it involves and why it might be beneficial for schemes and their members.
In addition, the Pensions Regulator (TPR) has updated its guidance on pensions dashboards to reflect the latest Money and Pensions Service guidance, feedback from the industry, and ongoing developments. The changes include:
- Updated guidance on voluntary connection.
- Updated guidance on choosing a digital interface.
- A new section on registration codes (which replaces the previous section on the registration process).
- Updated guidance on the connection process.
- New guidance on recording dashboards-related complaints.
TPR has also published a blog post on the importance of schemes having accurate data for pensions dashboards to be a success. Key points include:
- Trustees need to make sure they are taking the steps set out in TPR’s dashboards guidance and checklist. They should work with their administrators and (where applicable) their AVC providers to make sure their data is dashboards ready.
- Since October 2024, TPR has been targeting schemes based on data scores reported in scheme returns to ask how those schemes are reviewing their data and putting improvement plans in place. In the coming months, TPR will meet with the largest schemes to scrutinise their preparations for dashboards and will launch a campaign targeting the medium-sized schemes due to connect in 2026 to make sure they are on track to provide accurate data.
- Trustees need to change their mindset – and appropriately focus on and invest in their data. TPR expects trustees to involve administrators in strategic discussions, look at synergies between data projects, and explore what new technologies can do for them to improve data quality.
Lastly, the Pensions Administration Standards Association (PASA) has updated its guidance on data matching conventions. The updated guidance includes:
- A detailed roadmap for setting robust matching criteria.
- Best practice criteria for both “match made” and “possible match” responses.
- Guidance on:
- The use of unique identifiers.
- How data matching performance should be monitored and improved.
- How matching can support broader data improvement efforts.
Action No action required, but trustees and administrators of schemes that are subject to the dashboards requirements may find the TPR and PASA guidance helpful. Trustees and administrators of other schemes that are considering voluntary connection may find the PDP guidance helpful.
Pensions Commission – revival
The government has announced the revival of the Pensions Commission which will examine the pension system as a whole and look at what is required to build a future-proof pensions system that is strong, fair and sustainable. This will constitute phase two of the government’s pensions review. The Commission’s final report is due in 2027. The government has published the following in connection with the announcement:
- Terms of reference for the Commission.
- A policy paper assessing the state of Britain’s pensions landscape, including the progress made in the two decades since the first Pensions Commission.
The government has also launched the third statutory review of the state pension age.
Action No action required.
Systemic risks – TPR expectations
TPR has published a blog post on why being aware of, and managing, systemic risks is a core part of effective trusteeship. Key points include:
- Climate change, nature loss, and other systemic risks are not abstract concerns. Where they are financially material, trustees have a duty to understand and manage them as part of their fiduciary responsibilities. Strong investment governance is essential, especially in complex areas such as ESG and private markets.
- TPR is raising its expectations around investment governance. Trustees should ensure that decisions are long-term, well-evidenced, and subject to appropriate challenge.
- TPR encourages trustees to explore the Taskforce on Nature-related Financial Disclosures (TNFD) framework and use it to inform their thinking and ask better questions about risks such as deforestation, water scarcity, and ecosystem degradation.
- In a changing pensions and regulatory landscape, trustees should not just comply but should also lead. That means engaging with emerging frameworks like the TNFD framework, supporting credible transition plans, and embedding sustainability into investment strategies.
Action No action required, but trustees may wish to take TPR's expectations into account when reviewing their investment governance processes.
Net zero transition plans – TPR working group
TPR has announced the establishment of a working group to develop and test a voluntary net zero transition plan template for occupational pension schemes. The template will be based on the framework and guidance developed by the UK Transition Plan Taskforce and will be presented to the government later this year. The members of the group have not yet been appointed, but are expected to include trustees, advisers, and representatives of professional bodies.
Action No action required.
Issues affecting DB schemes
Pension Protection Fund – 2025/26 levy invoicing update
The Pension Protection Fund (PPF) has announced that it is putting invoicing for the 2025/26 levy on hold while it monitors the parliamentary progress of the PPF levy-related provisions in the Pension Schemes Bill. The PPF will keep schemes informed of progress and expects to provide a further update this autumn.
Action Trustees and employers of DB schemes should monitor further updates from the PPF.
Bulk annuity policies – solvency-triggered termination rights
The Prudential Regulation Authority (PRA) has issued a letter to chief risk officers of life insurers active in the bulk purchase annuity (BPA) market on the use of solvency-triggered termination rights in BPAs. The letter follows a thematic review by the PRA and sets out the PRA’s concerns and expectations and the next steps for insurers. In particular, the PRA is concerned that the widespread exercise of solvency-triggered termination rights could introduce significant risks to insurers' balance sheets. The letter sets out a number of mitigation actions that the PRA expects insurers to take, including a new requirement for insurers to promptly notify the PRA of any new BPA transactions containing solvency-triggered termination rights. For more information, please see our legal update.
Action No action required, but trustees of DB schemes considering or planning to purchase a bulk annuity policy should be aware that insurers may now be less willing to agree solvency-triggered termination rights.
De-risking – "jargon buster"
PASA has published a de-risking "jargon buster" which provides explanations of commonly used de-risking terms and options, including liability management exercises, buy-ins, buy-outs, capital-backed journey plans, and longevity swaps. It also outlines the administration and governance implications of each de-risking step, highlighting best practice and essential readiness tasks.
Action No action required, but trustees of DB schemes may find the jargon buster helpful when considering de-risking options.
Issues affecting DC schemes
Member support – proposals for "targeted support"
The Financial Conduct Authority (FCA) is consulting on proposals to introduce “targeted support”, a new regulated activity whereby authorised firms would be able to make specific recommendations in relation to pensions and retail investments designed for groups of consumers with common characteristics. Among other things, the consultation asks for views on:
- Whether trustees would want to provide a form of support like targeted support to their members and the nature of that support.
- More broadly, the type of support trustees want to offer their members and whether they feel unable to give such support because they are worried about undertaking a regulated activity or financial promotion.
The FCA will work closely with TPR and will consider if further clarity to trustees should be provided. The consultation closes on 29 August 2025.
Action No action required.
Maximising DC value – Employer Pension Pledge
The Lord Mayor of London has launched an Employer Pension Pledge. Under the Pledge, more than 20 of the UK’s largest employers have promised to maximise employee pension value by prioritising retirement outcomes for their workforce, rather than focusing on cost reduction, when selecting or reviewing their DC pension providers. The Pledge is separate to the Mansion House Compact and Accord. Signatories to the Pledge include Aberdeen Group, Aviva, BT, Canada Life, First Group, Goldman Sachs, L&G, London Stock Exchange Group, M&G, Mitie, Nationwide, NatWest, Octopus Energy, Octopus Investments, Phoenix Group, Prudential, Samworth Brothers, Santander, Schroders, Standard Chartered, Tata Steel, and Tesco.
Action No action required.
Mayer Brown news
Recent work
- Andrew Block advised leading private investment firm Sun European Partners on the pensions aspects of its affiliate's acquisition of Alton Cars.
- Liam Kellett advised Omni Partners and Infoshare+ on the pensions aspects of their acquisition of Sava Technology, a leading provider of energy analytics software to UK housing providers.
- Andrew Block and Lucy Moore advised CBPE Capital on the pensions aspects of its investment in Velociti Solutions, a market-leading provider of transportation software.
Updates
- Mayer Brown has been shortlisted in the Team of the Year and Innovation in New Product or Service categories at the PMI Pinnacle Awards 2025.
- Mayer Brown has been shortlisted in the UK Tax Law Firm of the Year category at the ITR EMEA Tax Awards 2025.
- Katherine Carter has been shortlisted in the Innovator of the Year category at the Women in Pensions Awards 2025.
Insights
- Inheritance Tax on Pension Death Benefits – Revised Proposals | Insights | Mayer Brown
- The PRA's Letter to Chief Risk Officers on Solvency-triggered Termination Rights | Insights | Mayer Brown
All our Insights are available here.
