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Pensions law update: August 2026

City of London Gherkin close-up with Shard in background

As has become customary in recent years, there were a host of legal developments in the first half of July as the DWP, HMRC and TPR all published key documents ahead of the summer recess. In this newsletter we bring you the latest edition of our PSA26 handbook, freshly updated to take account of these changes, alongside a summary of the key July publications.

We also look beyond the immediate reform agenda, with commentary on the Second Pensions Commission’s interim report and what it could mean for employers, the growing importance of cyber security as a covenant issue, and practical actions for schemes considering AI governance. Alongside our regular policy and governance updates, we share details of upcoming Burges Salmon events on AI in pensions and late-summer networking opportunities, as well as team news and recent pensions insights.

We have updated our Pension Schemes Act 2026 handbook to reflect the latest developments and timetable changes, following the July publication of the updated workplace pensions roadmap.

The handbook now encompasses the most recent publications on surplus law changes, new LGPS regulations and statutory guidance and the latest on key DC changes (including the value for money consultation and policy papers for the scale requirements and guided retirement). With our handbook you have up to date information on the changes affecting your scheme at your fingertips.

Read the handbook

Following the DWP’s publication spree in July, Rachael Skuse outlines some key developments as the implementation phase of the reforms under the PSA26 picks up momentum.

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Directors Jack Gillions and Andy Prater were delighted to sit down with Pensions Age magazine to discuss some of the key issues facing pension schemes during the current period of intensive reform – read their comments in this month’s edition (“Clearing a path” – page 56-58).

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The Interim Report published by the Second Pensions Commission is a comprehensive “state of the nation” analysis of the current UK pensions landscape. While the work of the Commission is continuing as it moves now to formulating its recommendations, there is a wealth of information in the Interim Report for us as an industry to consider.

In the first of two articles on the report, we’ve looked at what the Commission’s findings mean for employers:

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On 31 July 2026, the regulations which will enable the establishment of collective defined contribution schemes for multiple unconnected employers came into force. This is a change that it is hoped will galvanise the new CDC market, since it will allow commercial providers to offer CDC arrangements for the first time.

Alongside the implementation of the regulations, TPR’s updated CDC Code of Practice has also come into force. TPR has published a number of new and updated guidance documents to support the revised Code and the new multiple employer CDC arrangements.

Applications for multiple employer CDC arrangements to seek authorisation from TPR are now being accepted.

Visit TPR’s CDC homepage

How does cyber security and business continuity risk impact a pension scheme’s covenant? This is the topic Samantha Howell explores in our recent article, which looks at TPR’s approach to cyber security and covenant risk.

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HMRC’s July edition of its Pension schemes newsletter includes a reminder that all schemes need to have migrated across to the new HMRC Managing Pension Schemes service by 31 December 2026. The previous system, Pension Schemes Online, will close in April 2027, and may be dialled down ahead of that date, with some functionality potentially becoming limited as the closure date approaches.

There is also an update on changes to how schemes should contact HMRC – from 20 July 2026 emails sent to [email protected] will no longer be replied to directly. Instead, online queries and correspondence should be submitted via an online enquiry tool within HMRC’s new interactive guidance tool.

Chris Brown was delighted to join Aon’s David Burwell, Dom Makemson and Claire Cochrane on a recent webinar to discuss AI governance in pension schemes – he shares his top takeaways for trustees in this article.

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Burges Salmon and Quietroom: AI and Pensions – what works, what’s next?

On 10 September 2026, we will be co-hosting an event at our London offices with communications experts Quietroom on AI in pensions. We’ll be exploring who’s doing what, what’s working, and what’s round the corner – with plenty of practical insight throughout the event.

RSVP

Pensions drinks in Bristol

On Wednesday 23 September, we’re delighted to be hosting our late summer drinks event for clients and contacts at our offices in Bristol – we’d love you to join us.

RSVP

Pensions bites

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Team news

This month we’re celebrating a host of awards nominations. We’re delighted to be shortlisted in three categories at the PMI Pinnacle Awards – Team of the Year, Impact on Climate and Richard Knight for Leader of the Year. Congratulations to all of our fellow finalists and we look forward to the ceremony this Autumn.

And congratulations to Imogen Shelley, who has been shortlisted for Lawyer of the Year in the Professional Pensions Rising Star awards

View the announcement

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