Publication
Publication
Welcome to our Summer Edition of DC Agenda. And, at long last, it has arrived. No, not the balmy days of summer itself – rather the Pension Schemes Act 2026.
The Act has perhaps been the most contentious pensions bill of my career. Mandation of specific investments, of course, hit the headlines, as it was perceived as State interference in private property rights to an unprecedented degree.
To my mind, equally controversial was how little of the Bill’s substance could be fully debated in Parliament – because it just isn’t there. It will be in subordinate legislation, which is typically subject to less Parliamentary scrutiny. For example, the consequences of an “intermediate” VFM rating for a scheme will be set out (entirely) in regulations. The Act states these regulations “may” include various matters such as preparing an improvement plan – but neither mandates these matters, nor restricts regulations to these matters. Doubtless further detail will be in codes or DWP guidance. So, who knows what we might end up with? Personally, I am not entirely fond of such framework legislation.
It also makes it difficult to give our clients much valuable detail at this stage! However, as well as summarising the Act,this DC Agenda contains a very useful and important article on DC consolidation, which I recommend as a good read. Finally, we do now have detail in one area – the CDC Code (which we reported on in draft in our Spring 2026 edition of DC Agenda) has been finalised and we include an article highlighting the changes made to it in consequence of the consultation process.
We do hope you enjoy this edition of DC Agenda. As always, please do contact me or your usual Linklaters contacts with any comments or suggestions.