Pensions ping pong – where are we?

By Louise Pettit

27 Apr 2026 3 min read

It's a big week for the Pension Schemes Bill, with the Government under significant time pressure to get the Bill agreed before Parliament is prorogued ahead of the forthcoming local elections. Whether or not we'll get Royal Assent before the end of the current session is far from certain. The Bill is currently stuck in ping pong between the Houses, as the Lords hold firm on their resistance to the so called investment mandation reserve power for DC master trusts and GPPs (despite a number of Government concessions), .

The updates have certainly been coming thick and fast over the past week or two. As the investment mandation provision is now the final outstanding issue between the two Houses, we thought it would be helpful to round up which of the other key non-Government amendments that the Lords put forward have made it into the Bill:

Provision	Is it in the Bill?
LGPS
Amendments to interim employer contribution rate review regulations	No
Requirement to benchmark LGPS valuations against insurer pricing and gilt-based discount rates	No
New sub-clause clarifying that regulations made under Clause 2 (asset management) cannot prescribe asset pool companies are required to invest in a specific asset / asset class or location	No
Public sector
Review of sustainability of unfunded public service pension schemes	Sort of. The Government rejected the clause proposed by the Lords but, by way of concession, has inserted a new requirement for the Government Actuary to publish a document setting out cash-flow projections for the next 50 years within 12 months of Royal Assent.
DC
Extension of the time for which a small pot must remain dormant before it can be automatically consolidated from 12 to 36 months	No. The original Government proposed limit of 12 months has been re-instated.
Scale requirements exemption for well-performing schemes	Sort of – this is another area where the Government has made some concessions. The exemption clause proposed by the Lords was rejected as drafted. However, the Government has inserted new requirements that when it makes the scale regulations under the powers in the Bill, it must have regard to competition and innovation (the importance of which was stressed by the Lords) but also to the importance of scale, improving member outcomes and effective governance when making the scale regulations. Similar requirements will apply in relation to the measures regarding default arrangements. Further, the Government will be required to publish a report about the effects of consolidation on innovation in master trusts and GPPs within 12 months of Royal Assent.

So, as set out above, all of the other non-Government amendments are now resolved. In addition, the Government's own changes are agreed. We are therefore down to a single area of disagreement between the Houses but it is a significant one - whether the Bill should include a power for the Government to make regulations which would enable it to prescribe how master trusts and GPPs used for automatic enrolment invest their default funds?

The Government has already made two rounds of amendments to the power to seek to address the concerns raised by the Lords, including limiting the percentages of default funds in respect of which asset allocation could be prescribed to those specified in the voluntary Mansion House Accord commitment and tightening the scope of the power, which can now only be used once and will sunset off the statute book in 2032 if unused (and 2035 if used). With debates on the Bill scheduled for every day this week (if required), the Government is certainly pushing to reach a conclusion one way or the other before the end of the parliamentary session….