Current Issues - April 2026

Welcome to the latest edition of Current issues. This month, we cover a wide range of developments shaping the pensions landscape. From the Pension Schemes Bill moving closer to the statute book, to important updates on tax, regulation and dashboards, there is a lot for trustees, sponsors and advisers to consider. Below, we’ve highlighted key issues from this month’s publication. Click here to view the full edition.

Can we Bill it? (yes, we can, probably)

The Pension Schemes Bill has passed through the House of Lords, largely (though not entirely) intact. There were several reverses and setbacks for the Government along the way. It has the opportunity to repair some of the damage, but must do so before the end of the current parliamentary session, or the Bill will turn to rags in a puff of smoke, like Cinderella’s dress on the stroke of midnight.

Virgin territory: more navigational guidance

The Pensions Regulator has published guidance for trustees and managers of defined-benefit (DB) schemes
who might need to make use of the Virgin Media remedy contained in the Pension Schemes Bill. It outlines their legal responsibilities and the Regulator's expectations, whilst giving ‘practical tips’.

Tax text makes tracks

The Finance Act 2026 received Royal Assent on 18 March 2026. The Act contains provisions that:

• extend the Treasury’s power to make regulations connected with the abolition of the lifetime allowance;
• adapt the scheme-registration (and de-registration) powers and responsibilities of His Majesty’s Revenue and Customs’ to cover collective money purchase schemes; and
• bring some pension and lump-sum death benefits within the reach of inheritance tax (IHT), for deaths occurring on or after 6 April 2027.

Reserving judgement: master trusts

Following a review prompted by the Government’s desire to lighten the burden of regulation, the Pensions Regulator has updated its guidance on the minimum financial cushion that authorised defined-contribution master trusts (MTs) must hold.

The MT capital-reserving requirements are intended to ensure the financial sustainability of the arrangements. The Regulator says that it wanted to evolve its approach to reflect the lessons that it has learned in the seven years since the authorisation regime was put in place, and to free-up capital for productive use, leading to improved member outcomes.

FCA prioritises pensions

The Financial Conduct Authority (FCA) has outlined its priorities for the contract-based pensions and pensions advisory sector. Beginning in February 2026, the FCA took a new approach to communicating its priorities to the firms that it regulates.

It will now publish separate annual ‘Regulatory Priorities’ reports for each sector of the regulated community, rather than portfolio letters that firms build up a picture of the expectations relevant to their particular activities. The insurance sector was the first to benefit from the revised approach, but the FCA completed the suite of reports over the course of March, with the pensions-related instalment appearing on the 10th.

Thin gruel for peers critical of IHT reforms

The Government has responded to House of Lords Economic Affairs Committee observations on the pensions-IHT reforms. Although it says that it has ‘accepted 9 recommendations and partially accepted a further 31’, there are no further changes afoot to the policy or the compliance and tax-payment deadlines.

Some apparent concessions relate to changes announced at the time of the last Budget. Those include the option for a deceased member’s personal representatives (PRs) to give notice to scheme administrators to withhold taxable benefits for up to fifteen months, and the relief from liability that PRs may obtain in respect of
benefits discovered after His Majesty’s Revenue and Customs has given a discharge certificate.

PPF ties a bow on levy details

The Pension Protection Fund (PPF) has formalised its levy rules for 2026/27. As previously announced, its plans entail no levies for ‘conventional’ defined benefit schemes (those with substantive sponsoring employers),but continued imposts for the ‘alternative covenant’ variety (including superfunds).

Size matters

The Department for Work and Pensions (DWP) has published a document setting out its policy principles in relation to the defined contribution scale requirements in the Pension Schemes Bill. It is intended to provide context for a forthcoming consultation on implementing regulations.

The Bill will require master-trust and group personal pension schemes to have ‘main scale default arrangements’ (MSDA) with at least £25 billion of assets under management, by 2030, if they are to continue accepting automatic-enrolment contributions.

Dashboards: hits paraded & cavies craved

Pension status categories

The Pension Dashboards Project (PDP) published a blog setting out how the MoneyHelper Pensions Dashboard, which is being developed and operated by the Money and Pensions Service (MaPS), will display pensions search results to its users.

Feathering the NEST

The National Employment Savings Trust (NEST) is consulting on rule changes necessary to allow it to provide flexi-access drawdown and other benefits to members and survivors. Currently, NEST can only provide benefits in the form of lump sums or annuities.

Valuing actuarial regulation

The Financial Reporting Council’s (FRC's) plan for 2026/27 says that it will:

• maintain the Technical Actuarial Standards and related guidance (it mentions defined-benefit pensions, and the possibility of revisions to TAS 310, the standard that applies to collective money purchase schemes),complete the annual review of AS TM 1 (the technical rules for statutory money purchase illustrations); and
• develop its approach to the voluntary monitoring of actuarial work.

HMRC news: March 2026

Pension Schemes Newsletter 179 from His Majesty's Revenue and Customs (HMRC) includes the following:

• a new double-taxation agreement between the UK and Luxembourg may alter the tax treatment of UK-based pension payments to Luxembourgers;
• a reminder that, from 6 April 2026, scheme administrators of registered pension schemes must be UK resident, the online Managing Pension Schemes (MPS) service will have some downtime in early April whilst necessary changes are made;
• checks on members’ lifetime-allowance protections and enhancements are now only possible via MPS; and
• updates on progress toward making the administration of relief-at-source a digital affair (HMRC hopes to make changes during the summer to speed up its payment of tax relief; pension scheme tax references and scheme administrator IDs will need to be provided with claims from April 2026).

If you have any queries about this publication, please get in touch. 

This communication has been compiled by Hymans Robertson LLP® (HR) as a general information summary and is based on its understanding of events as at the date of publication, which may be subject to change. It is not to be relied upon for investment or financial decisions and is not a substitute for professional advice 
(including for legal, investment or tax advice) on specific circumstances. HR accepts no liability for errors or omissions or reliance on any statement or opinion. Where we have relied upon data provided by third parties, reasonable care has been taken to assess its accuracy however we provide no guarantee and accept no liability in respect of any errors made by any third party.