After a busy year in 2025 in the world of pensions, the start of a new year inevitably prompts us to look ahead to what 2026 might bring. When thinking about this, I reflected on the blog my colleague, Margaret Meehan, wrote at the start of 2024 which considered the pensions-related actions for 2024 and reflected on the LDI crisis of 2022.
Margaret commented that the lessons learned from the LDI crisis should not fade into the background with time and instead they should “serve as a beacon guiding trustees towards more robust, resilient, and adaptive strategies”. This included reviewing risk management frameworks and the resilience of investment strategies, underpinned by the pivotal role trustees play in safeguarding the assets of pension schemes.
Two years on, the pivotal role of pension scheme trustees is still front and centre, and the need for robust, resilient, and adaptive strategies is as crucial as ever.
There is a whole host of pensions developments expected in 2026, almost too many to mention here. Below is a list of the key ones:
- The Pension Schemes Bill is expected to receive royal assent early this year and is currently working its way through the House of Lords. The bill includes a long list of measures, including in relation to returning DB surplus to employers, the legislative framework for the authorisation of DB superfunds, scale and asset requirements for certain DC schemes, and provisions around consolidation of small, dormant pension pots, and value for money.
- The Collective Defined Contribution (CDC) schemes regime will also be extended to unconnected multi-employer schemes, and there are proposals to create a new type of ‘retirement’ CDC scheme to allow pensioner members to transfer their DC pots to a CDC scheme.
- Also of significance is the DWP consultation on trust-based schemes and the role of trustees and administrators, and standards for (and possible accreditation of) independent trustees. The consultation closes in March 2026, and we await the response with interest.
- The most widely publicised topic is likely the introduction of pension dashboards: 31 October 2026 marks the date by which all relevant occupational pension schemes and FCA-regulated providers must connect to the dashboards ecosystem. It is hoped that this will radically change how members interact with and understand their pensions savings. The industry will also have to navigate the proposed extension of the inheritance tax regime to pensions, and proposed restrictions on salary sacrifice for pension savings.
All in all, a busy 2026 for pensions. As predicted by Margaret at the start of 2024, trustees will need to continue to be robust, resilient, and adaptive to tackle the ever-increasing amount of regulatory change. We are here to help: please contact your usual contact in the pensions team or scheme governance team.
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