Summary
The pensions landscape is entering a new phase. In the Summer 2026 edition of Hot Topics, David Brooks, Head of Policy at Broadstone, explores the legislative, regulatory and market developments that are giving trustees and sponsors greater strategic choice, while also increasing expectations around governance and decision-making. This summary highlights the key issues to have on your radar, with the full guide available to download for detailed analysis and practical insight.
Surplus flexibility is moving from consultation to implementation
The Government’s consultation on surplus flexibilities marks an important shift in how well-funded defined benefit schemes are viewed. Rather than focusing solely on deficit reduction and buy-out, the proposed framework supports a wider range of endgame options, including the possibility of running schemes on where appropriate.
For trustees and sponsors, greater flexibility does not mean simpler decisions. Any consideration of surplus release will need to balance funding resilience, investment risk, covenant strength and member outcomes, making robust governance and long-term planning more important than ever.
Read more: A new Prime Minister – and the chance to move the pensions debate on
The Pension Schemes Act 2026 is reshaping scheme strategy
The Pension Schemes Act 2026 marks another step in the shift away from a one-size-fits-all approach to pension scheme management. For DB schemes, it expands endgame options through surplus flexibilities and a permanent framework for superfunds, while DC reforms focus on improving value for money, encouraging consolidation and strengthening retirement outcomes.
Together, these changes reinforce a broader trend rather than a single legislative event. Trustees and sponsors should consider how their long-term strategy, governance and scheme design will evolve as regulation increasingly supports larger, better-governed schemes and a wider range of endgame options.
Read more: The future of the State Pension: what’s changing and what’s here to stay
Inheritance Tax changes mean preparation should start now
Following the Finance Act receiving Royal Assent, most pension death benefits will fall within the scope of Inheritance Tax from 6 April 2027. While implementation remains some way off, it represents one of the most significant operational changes affecting pension schemes in recent years, requiring new processes for valuing death benefits and supporting estate administration.
Although the rules do not take effect until April 2027, preparation should begin well before then. Trustees and administrators will need to review governance, administration processes and member communications, while ensuring they are ready to work more closely with personal representatives and support the new tax framework.
Pensions Dashboards are entering the operational phase
With more than 70 million pension records now connected across the industry, pensions dashboards have moved beyond being a technology project and into operational delivery. As the statutory connection deadline approaches, the focus is shifting towards data quality, governance and member experience.
Connecting successfully is only part of the challenge. Trustees should be confident that their data, administration processes and ongoing oversight will support dashboards once members begin using them, rather than viewing compliance as the end of the project.
Read more: Do politicians keep changing UK pensions? The reality for ordinary savers and trustees in 2026
AI is bringing new governance responsibilities
Artificial intelligence is becoming an increasingly visible part of the pensions landscape, whether through administration, communications or data analysis. As its use grows, regulatory expectations are also evolving, with an increasing focus on governance, oversight and accountability.
AI may improve efficiency, but it does not reduce trustee responsibility. Trustees should understand where AI is being used across their scheme and by third-party providers, ensuring appropriate governance, risk management and cyber resilience remain in place while recognising that responsibility for member outcomes ultimately remains with them.
Read more: How inclusive design can improve workplace pension engagement
The Pensions Commission is shaping the next phase of reform
The interim report from the second Pensions Commission signals that the next phase of pensions reform is likely to focus on retirement adequacy rather than pension participation. While automatic enrolment has successfully increased pension saving, policymakers are increasingly considering whether current contribution levels are sufficient to deliver adequate retirement incomes.
Although the Commission has not yet made formal recommendations, trustees and sponsors should monitor its work closely. Its findings are likely to influence future policy on contribution levels, retirement income and pension provision, helping to shape the next phase of pensions reform over the coming years.
Read more: What Does Value Really Mean in Pensions? Why Peace of Mind Might Matter as Much as Performance
Also on trustees’ radars
Alongside the headline developments, trustees should also keep an eye on several other regulatory and legislative changes that will influence governance and administration over the coming months.
Transfers and GMP conversion
Transfer regulations continue to evolve, with consultations proposing refinements to transfer “flags”, while new tax regulations are intended to simplify GMP conversion following equalisation.
Although these changes are technical, they could help reduce administrative complexity and improve member experience. Trustees should ensure their advisers and administrators are prepared to implement any changes once confirmed.
Funding and endgame planning
The Pensions Regulator’s 2026 Annual Funding Statement reinforces that strong funding positions should be supported by clear long-term strategies, particularly as more schemes consider options beyond buy-out.
For trustees, this means funding decisions should be closely aligned with their endgame objectives. Sponsors should also use funding discussions as an opportunity to revisit long-term scheme strategy and journey planning.
Other legislative changes
Trustees should continue preparing for the increase in the Normal Minimum Pension Age to 57 from April 2028. The Pension Schemes Act 2026 also introduces changes to the Pension Protection Fund levy framework and provides a legislative solution to issues arising from the Virgin Media judgment.
While these developments may not require immediate action, they should remain on schemes’ governance agendas. Reviewing scheme rules, administration processes and member communications now can help avoid unnecessary complexity closer to implementation.
Key dates for pension schemes
- Summer 2026: The Government’s consultation on DB surplus flexibilities is underway. Trustees should use this opportunity to review their endgame strategy, governance arrangements and whether run-on could become a viable option for their scheme.
- Throughout 2026: Regulatory expectations around artificial intelligence continue to develop. Trustees should understand where AI is being used across their scheme and by third-party providers, ensuring appropriate governance and oversight remain in place.
- Throughout 2026: Trustees should continue preparing for legislative changes affecting transfers, GMP conversion and the Pension Protection Fund, ensuring governance, administration processes and scheme documentation remain up to date.
- Autumn 2026: The Pensions Regulator’s Annual Funding Statement will continue to shape scheme funding discussions. Trustees should ensure valuations support a clearly defined endgame strategy, particularly where schemes are well funded and considering options beyond buy-out.
- 31 October 2026: The statutory deadline for connecting to the Pensions Dashboards ecosystem is approaching. Trustees should ensure their scheme is not only connected, but also operationally ready, with robust data quality and ongoing governance processes.
- 6 April 2027: Most pension death benefits will come within the scope of Inheritance Tax. Trustees and administrators should prepare new processes for valuing death benefits, working with personal representatives and supporting the new tax framework.
- Spring 2027: The second Pensions Commission is expected to publish its final report. While no immediate action is anticipated, trustees should monitor its recommendations closely as they are likely to shape the next phase of pensions policy.
- 6 April 2028: The Normal Minimum Pension Age increases from 55 to 57. Trustees should review scheme rules, identify members with Protected Pension Ages where applicable, and ensure member communications are updated well ahead of implementation.
Download the full guide
This article highlights some of the most significant developments affecting pension schemes over the coming months, but it is only a summary.
For a more detailed analysis, including commentary on transfer regulations, GMP conversion, the Pension Protection Fund, the Virgin Media legislation, data protection changes, geopolitical risks and other key developments, download the complete Hot Topics Summer 2026 guide.
