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

In this 7 Days

TPR’s CDC code of practice consultation

TPR published a consultation on a revised draft code of practice for CDC schemes on 19 December 2025. The code of practice is designed to replace the existing code applicable to single and connected employer CDC schemes, to cater for unconnected multi-employer CDC schemes. The consultation closes on 13 February 2026.

On 15 December 2025, the unconnected multi-employer CDC schemes regulations were made. The regulations come into force on 31 July 2026 and establish a full regulatory framework for unconnected multi-employer CDC schemes.

For more information, please see our Alert.

Automatic enrolment thresholds to be maintained

On 18 December 2025, the DWP published its research and analysis following the review of the AE earnings threshold and qualifying earnings bands and has confirmed that for 2026/27:

  • the existing threshold of £10,000 for the earnings trigger will be retained, and
  • the current lower and upper earnings bands for qualifying earnings will be maintained (at £6,240 and £50,270 respectively).

TPR overview of DB landscape in 2025

TPR published its annual overview of the occupational DB and hybrid scheme landscape on 16 December 2025. Key findings include:

  • as with previous years, the DB and hybrid landscape continues to shrink at a yearly rate of 3% on average. Schemes continue to close, with the percentage closed to future accrual (excluding those in wind-up) rising from 73% in 2024 to 74% in 2025
  • membership in private DB and hybrid schemes has fallen by 3% since 2024 to 9,174,000, and
  • the percentage of schemes in surplus on a technical provisions basis is 82% in 2025 compared to 80% in 2024.

TPO overpayment factsheet

On 16 December 2025, TPO published a factsheet to help members and other beneficiaries of pension schemes understand overpayments. It hopes that the information will help both parties to work together to agree whether, how and over what period an overpayment should be recovered and so, in turn, “allow disputes to be resolved at the earliest possible stage.”

TPO suggests that schemes share the factsheet with members when informing them of an overpayment or when a member queries or challenges the scheme’s attempt to reclaim an overpayment, so members have a “better understanding of this complex area”.

Pensions schemes newsletter 176

On 18 December 2025, HMRC published its latest pensions schemes newsletter. It includes information on various pensions-related developments, including guidance on the new requirement for all tax advisers who interact with HMRC on behalf of clients to register and meet minimum standards.  It confirms that providing information to scheme members (for example, providing information about AA charges or holding pre-retirement information sessions) is not caught by the requirement to register “as there is no interaction with HMRC about the clients’ tax affairs”.

Best wishes for the festive season and 2026

This is our last 7 Days of 2025. The first edition of the new year will be published on Monday 5 January 2026.

With best wishes for 2026 from all at Sackers.