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Speculation is growing ahead of the Chancellor’s budget, due on 26 November, with think tanks and newspapers publishing reports on potential pensions tax changes that may or may not be under consideration.
More generally, pensions law reform continues to be all around. With that in mind, this month we launched our Pension Schemes Bill handbook – a guide to help stakeholders navigate the key changes being made by the Bill. One such change is the proposed s37 remedy, and in this edition we bring you the latest update from the Financial Reporting Council on the accompanying actuarial guidance.
This month’s newsletter also features the latest episodes of our Pensions Pod, a series of articles celebrating cyber security awareness month, an outline of key changes to data protection laws for pension schemes, new PASA guidance on use of AI in pensions administration and an update from the Pensions Ombudsman on benefit statement disclaimers. Last but not least, there’s also an exciting update on the growth of our team, as we welcome five new faces this month, including partner Gary Delderfield.
The changes the Pension Schemes Bill will make to the industry are wide-ranging and significant. And the Bill itself is just the start of a journey of reform that will span the next 5 years and beyond, with much of the detail to follow in swathes of secondary legislation and regulatory guidance.
We have designed a handbook to act as your companion during this period of change; guiding you through the key changes in a user-friendly, easy to digest way. It will be updated periodically to incorporate the latest updates as they happen.
Read the handbookAs we reported in September, the Pension Schemes Bill has been amended to include draft remedy provisions for schemes with historic scheme amendments where evidence of s37 compliance is incomplete.
In October, the Financial Reporting Council issued a statement advising that it is working with industry professionals, the Institute and Faculty of Actuaries and the Association of Consulting Actuaries to develop technical guidance to support scheme actuaries who are asked by affected pension schemes to apply the remedy. The statement advises that the guidance will be available “when the expected legislation comes into force”. The Bill is expected to become law in the first half of 2026, with the remedy provisions coming into force two months after the date of Royal Assent.
Read moreThe DWP has published its response to a consultation on collective defined contribution schemes for multiple unconnected employers, and has laid regulations designed to extend CDC provision in this way before Parliament. The response indicates the intention is that the regulations and an updated TPR Code of Practice will come into force on 31 July 2026.
Read the responseOn the same day, the DWP also launched a further consultation on a policy framework for what it calls “retirement collective defined contribution schemes”. These are CDC schemes designed for the decumulation phase – DC savers could transfer their pots into a retirement CDC scheme at retirement “into a collective fund that provides a trustee managed income for life, adjusted annually based on investment performance and scheme sustainability.”
Read the consultation
Podcasts
16 October 2025 • 10 min read
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30 October 2025 • 10 min read
Thought leadership
8 October 2025
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22 October 2025
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Legal updates
31 October 2025
Thought leadership
29 October 2025
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Date: Wednesday 12 Nov, 2025
Time: 4.00pm – 6.15pm
Location: Burges Salmon London office
Just a few places remaining now for our in person seminar exploring alternative journey plans for DB schemes. With a stellar line up of speakers, this is your opportunity to hear from the parties involved in the recent Clara superfund transactions and their advisers.
And we’d be delighted for you to join us after the seminar for networking over drinks.
Register now
It’s another very exciting month of growth for us as we are delighted to welcome five new lawyers to the team. Partner Gary Delderfield is a nationally recognised leader in public sector pensions law and joins us together with senior associate Alec Bennett to bring additional strength in depth to our public sector pensions practice.
Read moreWe are also very pleased to welcome senior associate Georgie Wardrop to our London-based team, and Jaimie Buchanan (PSL) and Megan Bruce (solicitor) to our Scottish office.
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.
Keep up-to-date with the latest developments in pensions law with our monthly “Pensions Law Update” newsletter. We will use your contact details to send you emails about the latest pensions news, thought leadership and events.
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Legal updates
31 October 2025
Podcasts
30 October 2025 • 10 min read
Thought leadership
29 October 2025
Thought leadership
22 October 2025
Podcasts
16 October 2025 • 10 min read
