Pensions Weekly Update – 1 April 2025

Here is our weekly summary of key legal and regulatory developments relevant to occupational pension schemes that you might have missed, with links for further information.

• The chancellor gave her spring statement on 26 March. It proved to be unremarkable from a pensions perspective. We are still waiting for the outcome of various consultations, including on consolidation in the defined contribution (DC) market, the Local Government Pension Scheme: Fit for the Future, options for defined benefit (DB) pension schemes and the final pensions investment review (phase one), which is expected in the “spring”, and we are also awaiting the pension schemes bill.
• The Pensions Regulator (TPR) has published a press release with links to its DB and trust based DC 2024 research findings. The survey questions asked of DB respondents included: the long-term objective for their scheme, the attraction of using a consolidator, the provision of discretionary benefits, investment in UK productive finance, awareness of TPR’s general code of practice, environmental, social and governance (ESG), pension scams and dashboards. The survey questions asked of DC respondents included cybersecurity measures that schemes have in place, investment in UK productive finance, awareness of TPR’s general code of practice, ESG, pension scams, dashboards and proposed changes to the eligibility criteria for automatic enrolment. Interestingly, of those surveyed, more than a third of DB schemes and more than a fifth of DC schemes had investments in UK productive finance.
• Nausicaa Delfas, CEO of TPR delivered a speech at the JP Morgan Pensions and Savings Symposium on 28 March 2025. In her speech, she notes that growth and pension investment are not necessarily in conflict and says that “…TPR will use its unique position in the market to engage with schemes and with government, and help to clarify the profile of potential assets that would best align with different types of schemes' objectives.” The speech links to TPR's response to a request by the government for five pledges to reduce regulatory burden and support economic growth, which we flagged in our weekly update of 18 March.
• HM Revenue and Customs (HMRC) has published newsletter 168. This reaffirms the importance of making sure that pension schemes are migrated over on to the new Managing Pension Schemes service. It explains how pension scheme returns will be requested by HMRC via the new system, and that returns must be submitted via the new online system. The following deadlines will apply for submission of a 2024 to 2025 pension scheme return:
• Schemes migrated over to the new service on, or before 31 October 2025 will have a filing deadline of 31 January 2026
• Schemes migrated over to the new service after 31 October 2025 will have a filing deadline for their 2024-to-2025 scheme return of three months from the date of issue by HMRC
• In our latest #how2dopensions quick guide, we take a look at some of the key signs of business stress, and distress, that pension trustees should be aware of when monitoring the strength of the employer covenant.
• Happy birthday to TPR’s general code of practice, which came into force on 28 March 2024. Matthew Giles, pensions partner, celebrates with a video of his top three tips for keeping compliance programmes on track.

If you would like specific advice on any of these issues or anything else, please contact a member of our Pensions team.