7 Days is a weekly round up of developments in pensions, normally published on Monday mornings. We collate this information from key industry sources, such as the DWP, HMRC and TPR.

In this 7 Days

DWP consults on guided retirement policy and draft regulations for retirement collective pension schemes

On 3 November 2026, the DWP published a consultation on guided retirement policy proposals for both contract-based and trust-based schemes. It also published a consultation on draft regulations for retirement CDC schemes (now referred to as “retirement collective pension schemes” or “RCPS”), alongside its response to its 2025 consultation.

Guided retirement is a key pillar of the Government’s agenda to turn DC pots into pensions and develop a pensions system that adequately supports people through retirement.

Trustees and providers will need to design and make available to eligible members one or more default pension benefit solutions (“default pensions”) and keep this under review. Schemes may provide their own solution(s) or, where “it is not reasonably practicable” for them to do so or the trustees consider another scheme’s solution would provide better outcomes, partner with another arrangement. However, the individual’s consent to the transfer will be needed. The consultation considers how the introduction of default pensions will operate in practice, and how it can be implemented across the market in a way that works for individuals and pension providers (including occupational pension scheme trustees).

RCPS will provide an income designed to last for life, and the Government intends that initially such schemes will be accessed through guided retirement. The two consultations have been published together deliberately, and respondents are encouraged to consider them together and reflect on “how each regime can support the other”.

The consultation on the draft RCPS regulations closes on 15 December 2026, followed by the consultation on guided retirement on 22 December 2026. The DWP expects to publish the Government’s guided retirement consultation response in Q3 2027, alongside a further technical consultation on draft regulations and a consultation on FCA rules.

See our Alert for more details on the consultations, and our hot topic for additional insight and opinion.

DWP consults on draft guidance on trustees’ fiduciary duties

On 5 November 2026, the DWP published draft guidance on “Pension fund investment: fiduciary and related duties of trustees”. Aimed principally at trustees of occupational pension schemes, the guidance is intended to clarify how existing legal principles apply to contemporary investment questions. It “does not introduce new duties or alter existing legal obligations”.

The consultation will run until 28 January 2027. See our Alert for details.

DWP responds to transfers conditions consultation

On 3 November 2026, the DWP published its response to its consultation on proposals to amend the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021 (the “transfers conditions regulations”).

As there was general support for most of the core proposals, the following changes will be introduced:

  • trustees will be able to make a transfer without engaging an additional level of due diligence where they are satisfied that the receiving scheme is “reputable”. The regulations will include a non-exhaustive list of factors to assist schemes with their assessment
  • the overseas investments amber flag will be removed
  • a new red flag where a transfer is proposed and the evidence provided does not demonstrate an employment link with the receiving occupational pension scheme. The Government intends to support trustees and scheme managers with details of the type of information and evidence which may be considered when making this assessment
  • a new amber flag for transfers into a SSAS where an employment or other relevant relationship has been demonstrated and the transfer is otherwise able to go ahead. This will require the individual to attend a MaPS appointment to provide guidance on the responsibilities, governance requirements and potential liabilities associated with participation in a SSAS, to help them make an informed decision about the transfer, and
  • members will be exempted from the requirement to take MaPS guidance where they have done so in the previous 12 months.

The Government has announced these measures now to give the industry an “early and clear view” of its intentions. Detailed guidance is due to be published alongside the introduction of the amendments, which are planned to come into force in April 2027.

Finance Bill 2026-27 published

The Finance Bill 2026-27 had its first reading in the House of Commons on 3 November 2026. The Bill contains the detail of some of the measures announced at the Budget 2026.

Provisions include the removal of the “two-year rule” for the tax treatment of pension death benefits. This will mean that certain death benefits will no longer become taxable solely because they are paid more than two years after the pension scheme administrator (generally, the trustees) first knew, or could reasonably have been expected to know, of the member’s death. The change will apply to payments made on and from 28 October 2026.

As reported last week, HMRC has asked pension scheme administrators to update their processes to ensure that tax is not deducted solely because a relevant payment is made or funds designated after the end of the two-year period. Some consequential amendments have been made to the PTM to reflect this.

The Bill also contains the tax legislation for authorised member surplus payments.

Outcome of automatic enrolment thresholds and alternative quality requirements

On 3 November 2026, the DWP published its annual statutory review of the automatic enrolment (“AE”) earnings trigger and qualifying earnings band. Alongside this, the DWP also published its response to the call for evidence on AE alternative quality requirements.

The current earnings trigger and qualifying earnings band thresholds remain unchanged and there are no plans to change the alternative quality requirements at this time. The Government notes that it is important to provide “continued stability” while the Pensions Commission is undertaking its wider assessment of the UK’s pension system.

TPR finds governance gaps between small and large pension schemes

On 4 November 2026, TPR reported its findings from the “2026 Trustee Survey”, which was carried out between 15 January and 6 March 2026. It aims to establish a baseline measure of governance across the market.

TPR found “significant governance gaps” between small and large pension schemes, with smaller schemes having less developed arrangements to spot and manage risks. 27% of small DC pension schemes had formal governance arrangements in place compared with 94% of large DC schemes and 89% of master trusts. TPR says the findings “present new expectations for trustees to benchmark their governance against its general code, strengthen succession planning and board development, and ensure governance and risk management arrangements are supporting good outcomes for members”.

TPR publishes regulatory intervention report

TPR has published details of a regulatory intervention related to a series of transactions involving the former employer of two DB schemes. TPR considered that the transactions had removed valuable covenant support without sufficient and appropriate mitigation, exposing members’ benefits to a foreseeable risk while the directors and shareholders of the former employer received significant financial benefits. Contribution Notices were sought and the case concluded through a settlement.

FRC launches review of pension illustrations

On 3 November 2026, the FRC launched reviews of how actuarial standards for pension illustrations should develop to continue supporting savers’ retirement planning. It is calling for feedback on AS TM1 for statutory money purchase illustrations, alongside a discussion paper in support of the consultation on guided retirement which seeks views on how future standards could support pension illustrations both before and throughout retirement. Feedback on both reviews is requested by 26 January 2027.

PPI publishes update to UK Pensions Framework

On 4 November 2026, the PPI published “How work shapes retirement outcomes”, its fifth report in the UK Pensions Framework series. This report explores how earnings and pension contributions shape retirement outcomes, highlighting the important role of workplace pension provision.