Pensions law update: April 2025

3 Apr 2025 6 min read

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Welcome to our April pensions law update.

On 26 March, all eyes were on the Chancellor’s Spring Statement but in the end there was little in there for the pensions industry. Whilst in some ways there was relief not to see further pensions policy changes announced, there had been some hope that the Statement might include updates on some of the measures already in train – for example, responses to the Options for DB schemes, LGPS “Fit for the Future” and IHT on pensions consultations, or the full response to Phase 1 of the Pensions Review. For now it seems we’ll be waiting a little longer for those “Spring” updates…

This month our newsletter focuses on topical issues such as greenwashing and what it means for the pensions industry, the changing face of journey planning for DB schemes, dashboards developments and industry responses to the proposed new UK Stewardship Code. There’s an important update on the relevance of the Virgin Media decision to public service pension schemes, and a round up of all the other pension law essentials this month.

Greenwashing and the pensions industry

What is greenwashing? And what are the particular challenges it presents for the pensions industry? In this guide, Kate Granville Smith, Suzanne Padmore, Victoria Barnes and Brandon Wong take a deep dive into the concept of greenwashing, delving into the legal risks and the steps trustees can take to manage these effectively.

Section 37 and public service pension schemes: an update

The pensions industry continues to await further updates from the courts and the DWP regarding the implications of the decision in the Virgin Media cases (regarding missing s37 actuarial confirmations for historic amendments in contracted out schemes).

A key aspect still awaiting clarification is the extent to which public service pension schemes are affected by the decision – as Mairi Carlin explains, the LGPS Scheme Advisory Board has now written to the Government asking it to engage on the issue as a matter of priority.

A turning point for pensions journey planning?

In this article Clive Pugh considers the growth in alternatives to the traditional buy out of benefits with an insurer, including capital backed journey plans and DB superfunds. What are the risks and opportunities presented by each and how can trustees assess which is right for their scheme?

Industry responds to UK Stewardship Code consultation

The FRC’s consultation on its new UK Stewardship Code closed on 19 February. In this article we consider the responses from the PLSA and the PPF which share a number of points of agreement.

New standards for cyber security in AI

AI continues to be a hot topic across the globe and the pensions industry is no exception. As the technology continues to evolve apace, the cyber security implications of AI are a key concern for many. With this in mind, the Government has launched a new voluntary Code of Practice for the Cyber Security of AI – we take a look at the key principles.

Impact of proposed IHT changes on SIPPs and SSASs

For providers of SIPPs and SSASs, the Government’s proposed changes to bring unused pensions within the scope of the IHT regime from April 2027 are likely to be of particular relevance. Alice Honeywill and Amy Davies look at why some technical issues mean the proposed changes will cause headaches for SIPP and SSAS providers.

Pensions dashboards update

April 2025 is a landmark month for the pensions dashboard programme as the first schemes reach their connection dates at the end of the month (30 April 2025). Andy Prater rounds up the latest dashboards developments in this update.

Pensions Bites

Companies House changes – director ID verification

In the March edition of this newsletter we shared an update from our corporate team on the new director’s identity verification requirements coming soon to Companies House (read more here).

Subsequently on 13 March 2025, Regulations were laid which bring into force further provisions of the Economic Crime and Corporate Transparency Act 2023. These include provisions relating to director ID verification coming into force on 18 March 2025, and others relating to failure to prevent fraud coming into force on 1 September 2025.

April tax protection deadlines

With the end of the tax year fast approaching on 5 April 2025, there are a number of deadlines for pension schemes to be aware of. In particular, any person wishing to apply for fixed protection 2016, individual protection 2016, or certain other specific lump sum allowance enhancements relating to the abolition of the lifetime allowance, must do so before 6 April 2025.

UK Pensions Awards: Innovation award nomination

We are delighted to have been shortlisted for the 2025 UK Pensions Awards in the category for Educational and Thought Leadership Initiative of the Year. The nomination reflects our innovative approach to pensions law and particularly recognises initiatives such as our General Code checklists and cyber security package offering. We look forward to the awards ceremony later this year!

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PMI’s Northern Ireland Regional Group Event, 14 May – “Whose surplus is it anyway?”

Our own Richard Pettit and Andy Prater are looking forward to taking part in the PMI’s Northern Ireland regional group event “Whose surplus is it anyway?” on the 14 May. The event, which Burges Salmon is also delighted to sponsor, will take the form of a panel discussion on Defined Benefit (DB) pensions scheme surplus. Richard will be discussing pension scheme surpluses with Gregor Law and Emma McAteer and then Andy will be outlining other key legal and regulatory developments in pensions. (Non PMI members are very welcome).

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Team news

At the end of March we held our annual team training away day, with pension lawyers and support team from across our Bristol, Edinburgh and London offices coming together. The day was a valuable opportunity for colleagues to convene and connect, and really brought home how exponentially our pensions team has grown over the past few years. The highlight of the day was our evening pub quiz social!

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