Pension Schemes Act 2026

This page is for trustees, managers and advisers of defined contribution (DC) and defined benefit (DB) schemes. It summarises new requirements and changes introduced in the Pension Schemes Act 2026 and links to further information. We have provided this information to support trustees and increase their awareness of the changes being brought in under the Pension Schemes Act 2026. 

We will update this page regularly as secondary legislation develops and we publish detailed guidance. We expect further clarification on implementation timings shortly, and these will be added to this page.

First published: 18 June 2026

DC scheme requirements

The Pension Schemes Act 2026 introduces new requirements which will apply to trustees of most DC schemes. Secondary legislation will set out the exact requirements and which schemes these apply to.

If you have concerns about your ability to meet these requirements, you may wish to consider transferring to a master trust and/or winding up the scheme if that would be in the best interests of your members.

Complete a value for money assessment

You will need to complete an annual value for money assessment. Initially, this is intended to be of the scheme’s default arrangement.

The new assessment is more detailed than, and different to, the current value for members assessment.

Trustees will need to:

• collect metric data related to investment performance, costs and charges, and service quality
• submit metric data for assessment and rating
• compare metric data against other schemes and relevant benchmarks
• publish assessment outcomes for each arrangement 

It’s expected that if a scheme does not demonstrate it’s providing value, the trustees will need to put a formal improvement plan in place. In certain circumstances, you may be required to transfer affected members to another scheme or arrangement.  

Further information

• Value for money framework: response to consultation, further consultation and discussion paper

We plan to publish guidance supporting the Department for Work and Pensions (DWP) consultation on value for money assessments in the summer of 2026.

Provide a default pension plan (decumulation)

You will need to provide members with a default pension plan that delivers a regular income in later life.

Trustees will be required to:

• design one or more default pensions considering the needs and interests of their scheme’s membership
• provide communications to members about these default pensions

Trustees may have the option to form partnerships to provide default solutions, if these cannot be offered within the scheme.

Transfer small pots to an authorised consolidator

In automatic enrolment schemes, small DC pots of £1,000 or less in default arrangements should be automatically transferred to an authorised consolidator if no contributions have been paid for at least 12 months.

Regulations are expected to set out details of the pots this applies to (and any exemptions), the criteria to become an authorised consolidator and the transfer process.

We would encourage trustees to prepare by strengthening data quality, for example by:

• auditing deferred pots to identify which ones are in scope for transfer
• cleaning and validating member data – such as contact details, National Insurance numbers, names, and historic contributions

See our data quality guidance for more information on maintaining high quality data. Our pensions dashboards guidance also has information on matching people with their pensions

Meet scale requirements (master trusts and group personal pensions)

Expected to be in force from 2030.

To be used for automatic enrolment purposes, group personal pensions and master trusts will need to have a main scale default arrangement of at least £25 billion in assets under management by 2030. This is the case unless the scheme is exempt or it qualifies for transition pathway relief or new entrant pathway relief. To be eligible for transition pathway relief, a scheme will need to have at least £10 billion of assets under management in a main scale default arrangement by 2030 and a credible plan for growth. Future regulations will set out more detail on these provisions.  

Further information

• Statement on new scale requirements for DC master trusts: transition pathway and credible growth plans

DB scheme changes

Statutory remediation introduced to address Virgin Media judgment

In force now.

The act introduced a legal remedy to support schemes affected by the Virgin Media vs NTL Pension Trustee II Ltd case. The remedy will allow governing bodies of schemes that were contracted-out on a salary-related basis between 6 April 1997 and 5 April 2016 to get written actuarial confirmation that historic benefit changes met the necessary standards.

Further information

• Guidance on potential remediation for past alterations to salary-related contracted-out pension schemes

Trustees granted new powers to release surplus

Expected to come into force in April 2027.

The act broadens access to surplus release to a wider range of schemes. It introduces a statutory override enabling trustees to distribute surplus even where the scheme’s trust deed and rules do not expressly permit this. The government is consulting on regulations that will set out further details on this policy. Subject to consultation and final regulations, surplus may be released only where specified funding conditions are satisfied. The expected conditions are likely to be on the scheme’s low dependency funding basis. 

Further information

• Statement on new defined benefit surplus flexibilities
• Guidance on new models and options in defined benefit pensions schemes
• Annual Funding Statement 2026

We plan to consult on detailed guidance in late autumn 2026.

Superfunds: introducing a statutory framework

The act introduces a statutory framework for authorising and supervising superfunds. This will replace our interim framework.

Further information

• DB superfunds guidance (interim framework)

Local Government Pension Scheme (LGPS)

The act introduced a number of reforms for the LGPS in England and Wales. These changes include:

• requirements on the LGPS to reform asset pooling which will be regulated by the Financial Conduct Authority (FCA)
• the strengthening of existing governance requirements, such as the introduction of independent governance reviews (IGR) and the requirement for schemes to appoint a senior LGPS officer

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