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Pensions law update: November 2026

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We begin with a round up of the key pensions measures announced in the Chancellor’s budget on 28 October 2026. From the new pension tax allowance to the abolition of the death benefits two year tax rule and tweaks to the April 2027 inheritance tax regime for pensions, there a number of small but important technical changes to be aware of.

AI continues to be the hottest of hot topics globally, and pension scheme governance is no exception. In this edition we bring you a number of important AI updates, including findings from a recent joint survey of scheme members we conducted with the LPPA, as well as all the latest guidance from the Pensions Regulator.

Plus we have the latest episodes of the Burges Salmon Pensions Pod, our reflections on recent experience of the superfund market and a round up of other key pensions law developments.

The Chancellor’s 2026 budget has been broadly characterised as one of a large number of small measures, and that holds true for pensions. Whilst there have been significant developments for the state pension in the form of future changes to the triple lock and a new pension tax allowance for those with incomes at or just over the new state pension, for occupational and personal pension schemes there are a number of other important but less high profile changes to be aware of.

Two administrative easements to draw attention to are (a) the removal of the “two year tax rule” in relation to payment of certain pension and lump sum death benefits and (b) changes to the tax rules around when a member’s benefits can be commuted for terminal illness.

More detail is set out in our article but a key point to note is that in both cases the easements are not expressed to be overriding. This means schemes will need to review their scheme rules to check whether changes flow through automatically or whether the existing positions have been hard-coded into their documents and will therefore need amending.

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In episode 2 of this season, Helen Norman is joined by Aon’s Emma Moore to discuss pension scheme data projects – what should trustees be doing, where are the challenges and how can technology support high quality data?

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Two podcast microphones on a desk

And in episode 3, Helen sits down with our Head of Family Law and Divorce, Sarah Hoskinson, to discuss pension sharing on divorce. Listen to the episode for helpful insights into some of the key challenges faced by pension schemes and their trustees when divorce cases arise.

Listen here

Focus on AI

We were delighted to partner recently with Local Pensions Partnership Administration (LPPA) to survey its member panel about their attitudes to AI. With almost 1,700 responses, the survey provides a valuable insight into both how members are using AI and what they expect from their pension scheme.

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And in a piece that draws on some of that survey’s findings, Mamunul Wahid has written an article for Pensions Age magazine, examining AI adoption in pensions and how the industry needs to balance innovation, risk and responsible governance when using AI.

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In this short video, Chris Brown highlights two recent developments in pensions and AI – the Pensions Regulator’s six principles for AI governance (as outlined at the recent Pensions UK conference) and a new report published by Pensions UK “2030 Ready: A pathway to AI adoption in pensions”.

Watch this video

Since this video was recorded the Pensions Regulator has published its guidance for trustees on the use of AI. You can read the guidance here, and do look out for our forthcoming article, where we assess what the new guidance means for trustees.

Alternative end-game solutions

Landmark six-scheme superfund transfer

We are delighted to have advised the sponsoring employers, part of the Marelli UK group, in relation to an industry first six-scheme transfer to a single section of the Clara Pensions DB superfund. Read more about the transaction in our press release.

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Reflecting on our experience in the DB superfund market, Clive Pugh shares some key aspects of a superfund transaction and how they can benefit schemes.

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Silhouette of a Managing Director looking out the window of a tall commercial building at sunset

31 October 2026 was a milestone date for the pensions dashboards programme, being the deadline for all in scope pension schemes and providers to connect to the dashboards eco-system. 

Whilst the dashboards launch date, currently slated for sometime in the 2027/28 financial year, may still be some way off, there are still plenty of developments for schemes and providers to keep abreast of, as Andy Prater outlines in this round up.

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The Pensions Regulator has published new guidance for trustees in relation to the investment side impact of AI – with the increasing role AI companies play in global markets, what steps should trustees be taking to understand and test their exposure to AI market risk? 

TPR’s new guidance identifies the issue, and explains what trustees need to understand when it comes to their AI investment exposure. It highlights how, as the influence of AI on markets grows, trustees may have a greater concentration AI risk in their scheme than they might realise. The guidance explains why it is crucial to look “under the bonnet” of the investment wrapper to understand the underlying asset. 

The importance of trustees having a “proportionate and clear communication plan which can be executed quickly” to prevent members of DC arrangements making poor financial decisions in the wake of an adverse market event is also noted.

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The Pension Protection Fund has confirmed that it is not proposing to charge a levy for conventional DB schemes for the 2027/28 levy year. This marks the third consecutive year of zero levy, a decision made possible for the PPF by easements to provisions that previously restricted the year on year increase in the levy that could be made, which were included in the Pension Schemes Act 2026.

There is also good news for “alternative covenant schemes”, which include DB superfunds, with the PPF confirming that it intends to pause the levy for these schemes for 2027/28.

The PPF has also published the response to its consultation on proposed changes to its s143 and s179 valuation methodology, confirming that it will proceed with the changes outlined. The headline is that for most schemes the changes are likely to lead to lower estimated value of liabilities (reflecting increased competitiveness in bulk annuity pricing).

We were delighted to host two excellent industry events in our Bristol office this month.

On 6 October we welcomed the Women in Pensions South West network for an event focusing on the topical issue of “Rewirement” and how individuals can take control of our careers, finances and life goals.

And on 15 October, it was the turn of the Society of Pension Professionals – we were delighted to host the Autumn pensions update and networking drinks for the SPP’s south west group. It has been fantastic to welcome so many of the local pensions community into our offices over the past few weeks.

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