📈 Markets | London, Edinburgh, Cardiff

MARKET PULSE UK

Decoding Markets for Everyone


Pension Schemes Act 2026 reshapes UK workplace pensions

The Pension Schemes Act 2026, published by legislation.gov.uk and given Royal Assent on 29 April 2026, is less a single reform than a reset of how UK workplace pensions are expected to work. Behind the legal drafting sits a clear policy direction: fewer weak schemes, more consolidation, more scrutiny of value, and more scope for regulators to step in when providers or trustees fall short. For savers, that does not mean an overnight change to contribution rates or retirement age. It does mean the pension pot built up through auto-enrolment is more likely, over time, to be measured, compared, moved or merged if regulators decide a bigger or better-run arrangement can do more with it.

The biggest structural change for defined contribution pensions is the new value-for-money framework. The Act allows ministers to require trustees and managers of money purchase occupational schemes to publish assessments, share standardised data and give schemes a rating ranging from **fully delivering** to **not delivering**. The data can cover service quality, investment performance, asset mix, costs, charges and even member satisfaction. That matters because the rating is not just a badge. If a scheme falls into an intermediate band, trustees may have to produce improvement plans, notify participating employers and, in some cases, stop taking on new employers. If a scheme is judged **not delivering**, the Pensions Regulator can push trustees towards an action plan and, where it believes members would be better off elsewhere, require transfers to another scheme or arrangement.

For employers, especially smaller firms using bundled workplace pensions, the message is practical rather than abstract. The scheme chosen for staff will face harder public comparisons on cost and outcomes, and a weak rating could make that scheme harder to sell or harder to justify. For providers, the pressure shifts beyond headline charges towards administration quality, governance, reporting and member service. The Act also leaves room for the Financial Conduct Authority to build matching rules for FCA-regulated firms. In plain terms, ministers are trying to stop the trust-based and contract-based sides of the market from operating to visibly different standards when the saver’s experience can be very similar.

The small pots chapter is the part many workers are most likely to feel over time, even if they never notice it happening. A pot counts as small if it is worth £1,000 or less, and dormant if no contributions have been paid for a prescribed period of at least 12 months and the saver has not recently taken a step to confirm or change the investment choice. Those pots can then be lined up for consolidation. The process is designed to be mostly automatic but not entirely silent. Schemes must send a transfer notice, set out a default destination and one or more alternatives, and give the member at least 30 days to respond. If there is no reply, the pot can be moved to an authorised consolidator. For workers with a string of short jobs, that could reduce the familiar problem of five or six tiny pension pots sitting in different places, each charging fees and none large enough to command attention.

The Act goes further by setting up a scale test for the biggest workplace pension vehicles, though not immediately. Regulations cannot bring the main scale requirement into force before 1 January 2030. When it arrives, relevant Master Trusts and group personal pension schemes will need approval for a main scale default arrangement, with the legislation setting a £25 billion minimum and allowing connected schemes to be counted together. There is a transition route for schemes around the £10 billion mark if they can show a credible growth plan, plus a separate pathway for new entrants with an innovative design. This is the clearest signal yet that Whitehall sees size as a route to resilience, bargaining power and better member outcomes. That may prove right in many cases, but the Act also recognises the risk of squeezing out smaller propositions by requiring ministers to take competition and innovation into account when using these powers.

Ministers have also kept open a more interventionist option on how default pension assets are invested. From no earlier than 1 January 2028, and only after a published assessment involving the FCA and the Pensions Regulator, the Secretary of State may require a prescribed share of main default funds to sit in qualifying assets such as private equity, venture capital, private credit, land, infrastructure and other unlisted equity. The legal caps matter: the rules cannot force more than 10% of those assets into qualifying holdings, or more than 5% into UK-specific holdings. For pension providers and asset managers, that is both a commercial opening and a warning. Government plainly wants more long-term pension capital flowing into productive finance, but the Act stops short of handing ministers a blank cheque. Schemes can also ask to be treated as exempt from the asset allocation test where meeting it is likely not to be in members’ best interests.

Away from private workplace saving, the legislation also tightens the government’s grip on Local Government Pension Scheme investment pooling in England and Wales. Scheme managers can be directed into or out of asset pool companies, funds other than day-to-day cash are expected to be held and managed through those pools, and managers must publish investment strategies covering responsible investment, local investment and asset allocation. The Act also enables independent governance reviews and even merger powers for separate local government pension funds. That will be read closely by councils, pool operators and local asset managers. Supporters will call it overdue simplification. Critics will note that ministers are taking wider powers over structures that have historically been shaped more locally.

Another notable shift comes at retirement. The Act requires occupational defined contribution schemes to design default retirement income options, described in the legislation as default pension benefit solutions, or to identify an external qualifying solution if they cannot do so well in-house. Communications must be in clear, plain language and timed around the point when members actually need to make decisions. In that guided retirement section, the legislation does not allow a member’s accrued rights to be transferred without consent, which is an important safeguard. Alongside that, FCA-regulated pension schemes get a separate route for providers to make unilateral changes to certain pension pots, including switching investments or transferring pots to another scheme, without individual consent in every case. That power is not unlimited: the provider must satisfy a best-interests test, obtain certification from an independent person and give notice first. Even so, it is a notable shift towards administrative flexibility.

The Act is broader still. It puts superfunds on a statutory footing, gives the Pensions Regulator a formal approval role over transfers into them, tightens rules around capital buffers and governance, and updates the framework for defined benefit surplus payments back to employers so future regulations can require actuarial certification and member notification. There are also changes touching the Pension Protection Fund, the Financial Assistance Scheme, public service pension cash-flow reporting and a bespoke power to create a new public scheme for members of the AWE Pension Scheme. The bigger point is timing. Although the Pension Schemes Act 2026 is now law, many of its most important changes still depend on later regulations, regulator rules and consultation. According to legislation.gov.uk, some powers started on Royal Assent on 29 April 2026, but much of the operational detail will arrive in stages. For providers, employers and trustees, this is the planning phase. For savers, it is the start of a market where being small, expensive or hard to justify will become steadily harder.

← Back to Articles