Current Issues - October 2025

Please see excerpts below from this month's Current Issues. Click here to read the full publication. 

I owe you nothing (ooh yeah, nothing at all)

The Pension Protection Fund (PPF) has confirmed its intention to set its 2025/26 levies at £zero. The announcement applies only to ‘conventional’ private-sector defined-benefit schemes. 

Pension Schemes Bill progress

At the beginning of September, the Government tabled upwards of 260 amendments to, and new clauses for, the current Pension Schemes Bill, ready for the first Public Bill Committee sittings. Notably, the changes put forward includes a much-desired solution to the Virgin Media conundrum, and the removal of a controversial provision from proposed new rules about Local Government Pension Scheme (LGPS) asset pools. The Government’s changes were all (or almost all—see below) successfully incorporated into the Bill; those put forward by other parties were not, although in a couple of places the Pensions Minister offered reassurances that similar provisions would be introduced at a later stage. Its Committee Stage completed (in jig time), the Bill as amended in Committee will now proceed to the next parliamentary hurdle.

Meet the new boss same as the old boss

The start of meteorological autumn (on 1 September) brought upheaval in Government, occasioned by the resignation of Angela Rayner as Secretary of State for Housing, Communities and Local Government, and the Deputy Prime Minister. For once, however, the UK pensions world remained (relatively) unruffled by a reshuffle.

No transfer due-diligence obligations prior to 2021

The Pensions Ombudsman has set out his stance about the steps expected, historically, before transfers were made out of occupational pension schemes. He found no legal obligation or duty of care that would have required a trustee, in 2014, to perform extra-statutory transfer due diligence and warn a member about the presence of scam ‘red flags’. The position may have been different had the transfer been from a personal pension, or if the trustees had undertaken in some way the due-diligence obligation; and it has, in any case, been changed by the Conditions for Transfers Regulations, which came into force in 2021.

DB funding analysis 

The Pensions Regulator has published its annual funding analysis for occupational defined benefit (DB) and hybrid schemes. This year’s report covers tranche 18 valuations, with effective dates between 22 September 2022 and 21 September 2023.

HMRC newsletters: September 2024

In Pension Schemes Newsletter 173, His Majesty's Revenue and Customs (HMRC) opens with a statement confirming that a member who takes a pension commencement lump sum (PCLS) or uncrystallised funds pension lump sum (UFPLS) cannot reverse the tax consequences simply by paying back the lump sum. That means, importantly, that the pension associated with a PCLS must commence within six months if the latter is not to be considered an unauthorised member payment, and subject to tax penalties. The statement mentions a similar cautionary note included in Pension Schemes Newsletter 165, in December 2024, following queries from members who took PCLSs or UFPLSs in response to pre-Budget press speculation that tax-free lump sum rights might be curtailed.  

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.