We may be reaching the end of 2026, but from a pensions perspective, there is still lots to look forward to before the end of the year.

Published: 3 November 2026
Authors: Rhiannon Barnsley-Bloomfield

What are some of the biggest changes this year?

2026 has seen lots of changes and long-awaited measures being introduced. The most significant development this year being the Pension Schemes Act 2026 receiving Royal Assent.

The biggest changes introduced by the Pension Schemes Act 2026 included:

• surplus flexibilities: under the new provisions the trustees of a pension scheme may, by resolution, amend the scheme rules to:

  • introduce a power for the trustees to make payments to the employer of the scheme out of scheme funds where no power currently exists; and
  • remove or relax any restrictions imposed by the scheme rules on any existing power to make payments to the employer of the scheme out of scheme funds

• Virgin Media remedy: the new legislation permits scheme actuaries to give retrospective written actuarial confirmation in relation to historic amending deeds which will treat amendments as having been validly made insofar as the contracting-out requirements are concerned

• DC Pensions:

  • scale requirements:  new requirements for DC multi-employer schemes to operate a main scale default arrangement which has at least £25 billion in assets under management from 2030 otherwise the schemes will no longer be qualifying schemes for auto enrolment purposes
  • contractual override mechanism: a contractual override for schemes regulated by the Financial Conduct Authority (FCA). Providers will be able to make “unilateral changes” to schemes without member consent
  • a new Value for Money framework for both TPR and FCA regulated schemes
  • automatic small pot consolidation for automatic enrolment schemes;
  • default pension benefit solutions (part of Guided Retirement): Trustees of DC schemes will be required to develop ways for members to receive their pension without the member having to make complex choices about how they want to receive those benefits.

What is expected before the end of the year?

There are still two months left in 2026, and there are a number of items still expected, many of which relate to the implementation of the Pension Schemes Act 2026. Some of these may fall into the new year, but the following are outstanding:

More information on the surplus flexibilities:

TPR is expected to launch a consultation on surplus guidance outlining the factors trustees should consider when deciding to release surplus between October 2026 and January 2027. A response to the 2026 DWP consultation on Surplus Flexibilities for Defined Benefit Pension Schemes: Unlocking Value for Employers and Scheme Members is also awaited. Given the surplus flexibilities are expected to come into force from 6 April 2027, more detail should be revealed soon.

Contractual override

His Majesty’s Treasury is expected to lay regulations on the contractual override mechanism between October 2026 and December 2026. The contractual override mechanism will allow providers of FCA-regulated schemes to make “unilateral changes” to schemes without member consent.

A response to the consultation on statutory transfers

A response to the 2026 DWP consultation on Protecting Pension Savers - Proposals to Amend the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021 is awaited. This may not be provided by the end of the year, if not, we expect the response to be published in early 2027.

Pressing ahead

In the few days since this article was first drafted, some of the outstanding items have already been published. This suggests that these outstanding items might be appearing soon, as DWP and the regulators look to finalise the last publications before the end of the year.

Guided Retirement

On 3 November 2026, the DWP published its consultation and the FCA published its discussion paper on Guided Retirement. The purpose of these documents is to seek views on the proposals for a Guided Retirement framework in both contract and trust-based workplace pension schemes. The proposals introduce provisions to ensure that individuals saving into DC workplace pensions no longer have to make complex decisions about how to access their pension benefits.

Draft regulations on retirement-only collective defined contribution (CDC) schemes

A consultation on draft regulations implementing retirement-only CDC was published on 3 November 2026. The Autumn Budget confirmed that retirement-only CDC will be legislated for in the Finance Bill 27-28. The first retirement-only CDC scheme is expected to be authorised and launched from the end of 2028.

What does this mean for trustees and employers?

Given the number of topics still outstanding before the end of the year, trustees and employers shouldn’t lull themselves into a false sense of security that there will be no material developments in 2026. If the above do not materialise before Christmas, trustees and employers should expect these items in early 2027.