Pensions law update: March 2026

Welcome to the March edition of our monthly Pensions Law Update.

Will this be the month the Pension Schemes Bill receives Royal Assent? As set out in our update below, proceedings are certainly continuing apace with the report stage beginning in the House of Lords on 16 March.

As well as the latest on the Bill, this newsletter includes articles on the PPF’s 2026/27 zero levy announcement, key governance deadlines (including ORAs, overseas administrator changes and dashboards connections), and a number of FCA consultations, including value for money, regulating the changing pensions market and ESG ratings.

We also include insights on an interesting new claim relating to a pension fund’s wind farm investment, potential reforms to the Lifetime ISA, and the first of two responses to MHCLG’s consultation on access and protections in the Local Government Pension Scheme. And, last but not least, an update from us on a period of remarkable growth for our Pensions team.

Policy update

Pension Schemes Bill update

On 23 February the House of Lords Committee stage concluded and an updated version of the Bill was published, incorporating only those minor changes that had been agreed by the Committee. The report stage, an opportunity for further scrutiny and amendment in the Lords, begins on 16 March, with further sittings currently listed for 19 and 23 March.

As the Bill nears the business end of the parliamentary process, a Spring date for Royal Assent still looks to be achievable, though whether that will come before the Easter recess is still not clear. With the deadline for implementing major pooling reforms in the LGPS set for 31 March, we anticipate the Government will be doing all it can to ensure the Bill passes before that date.   

An updated version of our Pension Schemes Bill handbook, incorporating the amendments from the 23 February edition of the Bill and other recent developments, will be available shortly.

PPF levy

The PPF has confirmed that it will not be charging conventional DB schemes a levy for the scheme year 2026/27. Louise Pettit outlines key points from the PPF’s press release, including the position for schemes with existing contingent assets.

Focus on governance

Deadline for first ORAs approaching – what do trustees need to do?

With the deadline for the first wave of Own Risk Assessments or ORAs under the General Code fast approaching for many schemes, we share our thoughts on how to approach the exercise.

As we’ve highlighted previously, for schemes with a year end of 31 March, the first ORA must be completed before the end of March 2026. If you have questions about completing your scheme’s ORA, please do get in touch with Susannah Young or your usual Burges Salmon pensions team contact.  

Scheme administrator changes – are you ready for 6 April 2026?

A reminder that the law in relation to scheme administrators is changing – on and from 6 April 2026 it will be a legal requirement that a registered pension scheme’s scheme administrator is resident in the UK.

As we’ve highlighted in previous updates, for most trust-based schemes, the “scheme administrator” for these purposes means the trustees (rather than the in-house or third party administrators appointed by the trustees to act as the day-to-day administrators of the scheme). As set out by HMRC in newsletter 177, non-UK resident scheme administrators need to take action to remove themselves from HMRC’s online services as a scheme administrator before the 6 April deadline in order to remain compliant.

Schemes that have not already done so should therefore take action to remove any non-UK resident trustees who are registered with HMRC’s online services as scheme administrators this month in order to comply with the 6 April deadline. If you have any questions or need any assistance, please do get in touch.

Dashboards de-mystified

Have you requested access to our free dashboards resources yet? With the final dashboards connection deadline in October this year, we have designed some helpful products to assist schemes and their sponsors who are 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.

Please do get in touch to request access to our dashboards resources.

Cyber Security and Business Continuity – practical tips from our recent webinar mini-series

Samantha Howell shares the poll results and associated practical tips from the recent webinar mini-series she hosted jointly with Amy Khodabandehloo and Karla Gahan (Head of Resilience Services at Barnett Waddingham).