Pensions law update: September 2026

PSA26 reforms

Surplus law changes: the employer perspective

We examine actions that sponsors of DB schemes should be considering now, ahead of the planned implementation of the surplus law changes under the PSA26, currently scheduled for April 2027.

Value for money changes

As we highlighted in July, TPR, the FCA and the DWP are currently consulting on the proposed value for money framework to be implemented under the PSA26. The consultation has been extended by two weeks and now concludes on 15 September 2026.

The consultation proposals are detailed and technical, with the paper running to some 193 pages. To assist trustees and independent governance committees, TPR has published an overview for trust-based DC schemes alongside a digital service technical overview document. The scheme overview is a useful summary of the provisions to help trustees digest the new requirements. The technical overview is designed as a practical digest of the proposed digital solution and is designed to allow schemes to start to prepare for the first round of data submissions in 2028.

Visit our PSA26 webpage

Did you know we have a dedicated webpage for the PSA26 reforms?

As well as the latest edition of our handbook (updated on 5 August 2026 to account for the latest publications from the DWP, TPR and HMRC), you’ll find timelines outlining key DB and DC milestones and a library of our thought leadership articles, all organised by theme for ease of navigation.

AI in Pensions

AI and IDRPs

With use of AI technologies becoming rapidly more widespread, we consider what impact this has on member IDRP complaints – and how trustees might need to adapt their approach in response.

AI, vulnerability and customer outcomes

In this article we consider the findings of a recent report by the Payments Association – “How AI-powered banking tools are failing vulnerable customers” – and identify practical tips for pension providers and financial services firms to improve outcomes for customers.

Governance

April 2028 NMPA increase

Normal minimum pension age will increase from 55 to 57 on and from 6 April 2028. This means that the minimum age at which members can draw their benefits without them being taxed as unauthorised payments will be 57 (note, this does not prevent scheme rules specifying a higher minimum, or in some cases satisfying the conditions to retain a protected pension age of 55).

HMRC is currently consulting on draft regulations to implement transitional protections for members aged 55 or 56 who become entitled to their pension or a lump sum before 6 April 2028, but do not receive the first payment until on or after this date. The risk is that without transitional arrangements being in place such payments become unauthorised. The draft regulations set out proposed transitional measures designed to address this scenario.

The consultation closes on 28 September 2026.

Dashboards developments

With the final dashboards connection deadline looming large on the horizon next month, for many the focus has already turned from initial connection to ongoing compliance (including member matching and pension value data), user testing and preparations for
public launch.

In this article Andy Prater summarises key recent developments, including a helpful FAQ document published by PASA to assist schemes with answering member queries.