Current Issues February 2026

Virgin Media case – actuarial guidance

The Financial Reporting Council has published non-mandatory guidance for actuaries on providing retrospective confirmations under the proposed Virgin Media remedy in the Pension Schemes Bill. The guidance clarifies key concepts such as what it means to be “reasonable to conclude” that a scheme continued to meet the reference scheme test and promotes a proportionate approach to evidence gathering. The FRC says the guidance is intended to help actuaries prepare ahead of Royal Assent and may be updated as legislation progresses. TPR is expected to issue complementary trustee guidance in spring 2026. FRC guidance

Transfer protections – government to consult

The government has confirmed that it will consult in 2026 on strengthening protections in the pension transfer process. Ministers say the review will build on existing trustee powers to block high-risk transfers and will form part of wider efforts to combat pension scams. The Department for Work and Pensions is developing further measures in conjunction with law enforcement, the National Economic Crime Centre and industry bodies, with a public consultation expected later this year.

Risk transfer – PASA guidance on administration

PASA has published new practical guidance on managing scheme administration through buy-in and superfund transactions. The guidance challenges the assumption that administration activity reduces once a buy-in is completed, highlighting the importance of effective administration before, during and after transition. It focuses on common pressure points including data quality, rule alignment, member communications, deferred members and resourcing, and draws on real-world experience to help schemes plan early and avoid delays. PASA Guidance

Risk transfer – PASA guidance on administration

PASA has published new practical guidance on managing scheme administration through buy-in and superfund transactions. The guidance challenges the assumption that administration activity reduces once a buy-in is completed, highlighting the importance of effective administration before, during and after transition. It focuses on common pressure points including data quality, rule alignment, member communications, deferred members and resourcing, and draws on real-world experience to help schemes plan early and avoid delays. PASA Guidance

HMRC ‘Administrator’ – change to residency rules from April

From 6 April 2026, all administrators of UK-registered pension schemes must be UK resident for tax purposes. This change means that any individual trustees or directors registered with HMRC as Scheme Administrators who are not UK resident will need to be removed and replaced before that date. UK-registered corporate administrators are unaffected. Schemes should identify their registered administrators now and take steps to ensure compliance, particularly where authorised practitioners will need to be reappointed. HMRC’s Pensions Schemes Newsletter 174 provides further detail.
Pensions schemes newsletter 174 — October 2025 – GOV.UK

TPR Scheme Return

The Pensions Regulator has encouraged trustees to begin preparations for the 2026 DB and hybrid scheme return. TPR has published details of changes to the return and confirmed which sections of Exchange can be updated in advance of the scheme return notice being issued. Information entered early will feed directly into the return, potentially reducing time pressure later in the year. Trustees may wish to review data and governance information now to ensure it remains accurate and complete. DB and hybrid (mixed benefit) scheme return