Current Issues January 2026

DWP Consultation

The Department for Work and Pensions has launched a wide-ranging consultation on improving standards of trusteeship, governance and administration in trust-based pension schemes. Proposals include minimum accreditation standards for professional trustees, limits on trustee tenure and the number of appointments held, and stronger oversight of administrators and integrated service providers. The consultation also explores the role of member views and the potential case for a public trustee. Responses are invited by 5 March 2026.  The consultation documents can be found here: DWP Trustee & Governance consultation

TPR – Administration guidance

The Pensions Regulator has issued revised administration guidance applying to all scheme types. New areas of focus include stronger trustee oversight of administrators, broader performance measurement beyond turnaround times, and clearer expectations around IT system governance. The guidance builds on themes highlighted in TPR’s recent market oversight work on data quality and administration standards and reinforces that trustees retain accountability even where services are outsourced.  The guidance can be found here: TPR Administration Guidance

HMRC Scheme Returns

In HMRC’s Pensions Schemes Newsletter 176, published in December 2025, stakeholders are reminded that the pension scheme return for the 2024/25 tax year must generally be submitted by 31 January 2026. Schemes that migrated to HMRC’s Managing Pension Schemes service after 31 October 2025 will have a filing deadline of three months from their notice to file. Returns are more detailed this year and penalties will apply if Scheme Returns are not filed on time.  Atkin has contacted all clients about completing Scheme Returns (if requested by HMRC) and the deadlines that apply if Trustees wish for us to draft the Scheme Return on their behalf. 

Pensions UK – updated stewardship and voting guidance

Pensions UK has published its 2026 stewardship and voting guidelines, aimed at supporting trustees and advisers in promoting responsible investment and effective stewardship. The guidelines provide a framework for engaging with companies and exercising voting rights to influence corporate behaviour, with a continued focus on long-term value, governance standards and systemic risks.  The guidance can be found here: Pensions UK Stewardship & Voting Guidance

Pensions Ombudsman – overpayment factsheet

The Pensions Ombudsman (TPO) has published a new factsheet to help pension scheme members and beneficiaries understand key issues when a pension has been overpaid. Schemes are encouraged to share this information with members when advising of an overpayment, or if a member queries a scheme’s attempt to reclaim overpaid benefits, to support clearer understanding of this complex area.  The factsheet can be found here: Pension overpayments – Information for members | The Pensions Ombudsman