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Pensions Legal Outlook 2024

Key topics for you to prepare for in 2024

Pensions Legal Outlook 2024

In our Pensions Legal Outlook, we predict the key issues for occupational pension scheme trustees and sponsoring employers in 2024.

Some of the topics covered below have been key themes for the last few years, including buy-ins and buy-outs and ESG. Others are long-awaited developments which may finally come to fruition in 2024, including scheme funding, notifiable events and the Pensions Regulator’s general code of practice. We also cover several growing areas of interest, such as pension scheme surpluses and collective defined contribution schemes.

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Key themes

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2023 was another busy year for buy-ins and buy-outs, with the largest buy-in to date earlier in the year, a new insurer entrant and further longevity swaps, including the first to cover members still accruing benefits. The volume of deals for this year is expected to be £50bn. This does not look like it will be slowing down, with an even higher volume expected in 2024 and more new insurers predicted to enter the market. Meanwhile, the Government has confirmed its intention to proceed with a legislative framework for the regulation of defined benefit (DB) “superfund” consolidation schemes, although it is likely to be some time before this is in place. In the meantime, the Pensions Regulator has established an interim process for assessing DB superfunds, with the first transaction completing recently. We expect more to follow in 2024.

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Scheme funding, surpluses and investment

A new scheme funding regime is finally expected to come into force in 2024, although given the passage of time since the new regime was first mooted and the very different circumstances in which schemes find themselves today, it is possible that some aspects of the original proposal will change before it reaches the statute book. Meanwhile, the Government has said it will launch a consultation this winter on measures to make surplus extraction easier, a development which trustees and employers will watch with interest. On the investment front, ESG remains a hot topic for trustees, with the recent publication of the Taskforce on Nature-related Financial Disclosures (TNFD) recommendations and the Taskforce on Social Factors draft guide providing food for thought for the coming year.

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Mansion House reforms

Earlier in the year, the Chancellor of the Exchequer, Jeremy Hunt, delivered his Mansion House speech, setting out a package of reforms aimed at supporting growth across the economy and increasing returns for savers. Reforms to the UK pensions market featured prominently and have the potential to impact significantly on trustees and employers. They include a new value for money assessment framework for defined contribution (DC) schemes, a proposed automated consolidation solution to the problem of small pots and a new decumulation framework to support individuals at the point when they access their pension savings, as well as the proposed extension of collective defined contribution (CDC) provision to accommodate unconnected multi-employer schemes. The Autumn Statement built on the Mansion House proposals and we expect these reforms to top the Government’s pensions agenda in 2024.

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Abolition of the lifetime allowance

The pensions-related announcements in the Spring Budget 2023 were the most significant for some years and included the announcement that the lifetime allowance would be abolished from 6 April 2024. The Government has since published draft legislation to repeal the provisions of the Finance Act 2004 relating to the lifetime allowance. But the changes go further than this and include the introduction of two new allowances for lump sums. For many registered pension schemes, the changes are likely to have an impact on the benefits and options provided by the scheme, and it may be necessary to amend scheme rules as a result. Thinking through the implications is going to be a key priority for trustees and employers in the early part of 2024.

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Legislative and regulatory changes

A raft of further legislative and regulatory change is expected in 2024. We may finally see several long-awaited developments come to fruition, including a new notifiable events regime and the Pensions Regulator’s general code of practice. Meanwhile, although the timetable for schemes to connect to pensions dashboards has been delayed, we expect that schemes will be asked to start connecting from autumn 2024. We also hope the Government will address the issues trustees have been experiencing when operating the new red and amber flag regime for pension scheme transfers. Finally, we are expecting draft regulations to implement changes to the scope of auto-enrolment.

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