Pensions law update: February 2026

Focus on governance

Pensions dashboards: we can help

With the dashboards connection deadline in October this year, this month we were pleased to launch two brand new free resources to assist schemes and their sponsors navigating the complexities of dashboards connections. Our pensions dashboards tool is a user-friendly resource designed to digest and summarise the relevant legal requirements, whilst the dashboards checklist sets out the essential steps trustees need to take to ensure compliance.

Administration in the spotlight

The Pensions Regulator issued updated administration guidance in December 2025 – Andy Prater considers the new guidance and identifies actions trustees should be taking now, including putting in place a written administration policy or strategy.

Conducting your scheme’s first ORA – is your scheme ready?

Under the General Code schemes with more than 100 members are required to undertake an own risk assessment (ORA) to evaluate their ESOG (effective system of governance). The deadline for completing the first ORA is within 12 months beginning with the last day of the first scheme year that began after the General Code came into force (28 March 2024). For example, if a scheme year began on 1 April 2024, the deadline for completing the first ORA will be 31 March 2026. Therefore, in practice, for many schemes this means the ORA is due in the coming weeks and months.

Designed to go beyond the risk register, and with an emphasis on a meaningful evaluation of how the ESOG is operating in practice, undertaking your scheme’s first ORA may be daunting prospect for trustees. Early engagement is advised and we are very well placed to assist you with understanding what is needed and how you can undertake an ORA that meets all the requirements of the General Code, in a way that is proportionate and appropriate for your scheme.

For more information please get in touch with Susannah Young or your usual Burges Salmon pensions team contact.

PPF levy 2026/27

In the consultation which closed on 5 January 2026, the PPF proposed a zero levy for conventional DB schemes for 2026/27. Note that it is still proposing to charge a levy for alternative covenant schemes (such as superfunds). You can read more about the background in the PPF’s press release here.

The outcome of that consultation is expected imminently, but in view of the continued progress of the Pension Schemes Bill (the levy measures in which have yet to meet significant opposition), and the ongoing strong funding position of the PPF, significant departure from the proposals is not anticipated. Note that for technical reasons there is facility to fall back on last year’s 2025/26 levy rules if the Bill does not make sufficient progress before 31 March 2026. The 2025/26 levy rules also allow for a zero levy to be charged.

We hope you find the above helpful but, as always, please do get in touch if you have any questions or you would like to discuss anything further.