Current Issues July 2025

TPR Guidance on DB Scheme Options

On 3 June, TPR issued guidance on the endgame options available to trustees of DB and hybrid schemes. It outlines key considerations, including surplus extraction policies, risk tolerance thresholds, and collaboration with employers. Trustees are encouraged to detail surplus strategies in their statement of strategy under the new DB funding regime. Additional guidance is expected following future legislation. Read more: New models and options in defined benefit pensions schemes | The Pensions Regulator

Final Guidance on Statement of Strategy

Following its consultation, TPR has confirmed that DB trustees must submit a statement of strategy within 15 months of valuations dated after 22 September 2024. The Regulator has scaled back data requirements for “small” (fewer than 200 members) and “low-risk” schemes. The new digital submission platform will simplify the process, and key data areas such as covenant detail and investment breakdowns have been streamlined. Details here: Scheme valuation | The Pensions Regulator

HMRC Relaxes VAT Rules for Investment Costs

HMRC has announced that, from 18 June 2025, employers may reclaim all VAT on DB pension scheme investment costs, removing the previous “dual use” requirement. This change simplifies VAT recovery and can apply retrospectively for four years. Guidance on the new approach will follow in autumn 2025. See Revenue and Customs Brief 4 (2025):                                           

 VAT deduction on the management of pension funds – GOV.UK                                       

PPF Levy Flexibility Update

The PPF has welcomed legislative measures that enable further reductions to the conventional levy. Although the levy estimate for 2025/26 was cut to £45 million, the Board may set a zero levy if the legislative changes progress sufficiently. A final decision will follow later in the year. An update to levy payers is expected by the end of July. Details: Our comment on the introduction of the Pension Schemes Bill | Pension Protection Fund

Mortality Projection Model Updated

The Institute and Faculty of Actuaries’ Continuous Mortality Investigation has released the final version of its “CMI_2024” mortality projection model. It replaces earlier pandemic adjustments with an explicit overlay for excess deaths, tapering over time via a new “H” parameter. The model captures varying mortality trends by age and may increase life expectancy assumptions—by around three months for men and two weeks for women at age 65. Trustees should review model parameters with their actuaries.

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