HL UK Pensions Law Digest 4 August 2025

Welcome to our latest update, in which we cover: 

Pension Protection Fund: levy invoicing on hold

• PPF has put its levy invoicing for 2025/26 on hold while it monitors the progress of the Pension Schemes Bill;

HMRC Newsletter 171

• A reminder from HMRC of the recent changes to its plans for inheritance tax (IHT) to apply to some pension scheme death benefits;

Pensions Regulator: managing systemic risk

• A blog from TPR encouraging trustees to improve investment governance in relation to systemic risks; and

Pensions Ombudsman: Corporate Strategy and Corporate Plan

• The Ombudsman’s plans to streamline its own service, while encouraging better complaint handling by schemes.

Pension Protection Fund: levy invoicing on hold 

The Pension Protection Fund (PPF) has announced that it is putting its invoicing for the 2025/26 levy on hold. The announcement follows the introduction of the Pension Schemes Bill, which includes provisions allowing the PPF to charge a zero conventional levy.

The PPF intends to monitor the Bill’s progress through Parliament before making a final decision on whether to charge a levy for 2025/26.

The PPF plans to issue a further update to levy payers this Autumn.

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HMRC Pension schemes Newsletter 171 

HMRC has issued Newsletter 171, which includes:

• An explanation that HMRC has altered its approach to bringing some death benefits from pension schemes within the scope of inheritance tax (IHT). For our detailed consideration of the changes, please click here; and
• An explanation that administrators and practitioners must now use the Managing pension schemes service to update HMRC and to fulfil pension reporting requirements.

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Pensions Regulator: managing system risk 

The Pensions Regulator (TPR) has issued a blog by Mark Hill, Climate and Sustainability Lead, who argues that managing systemic risk is core to trusteeship. The blog explains that TPR is raising its expectations for investment governance, including how trustees are incorporating systemic risks into their investment governance. Trustees are encouraged to:

• Explore resources from the Taskforce on Nature-related Financial Disclosures (TNFD) framework and consider how their schemes may be impacted by nature-related risks;
• Use the environmental, social and governance (ESG) content on TPR’s Trustee Toolkit to build their knowledge and skills;
• Engage with the government’s consultation on requiring financial institutions, including pension schemes, to develop credible transition plans (consultation closes on 17 September); and
• Submit written evidence to TPR’s working group on transition planning (by email to esg@tpr.gov.uk by 1 September 2025).

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Pensions Ombudsman: Corporate Strategy and Corporate Plan

The Pensions Ombudsman (TPO) has published its three-year Corporate Strategy (2025-2028) and Corporate Plan for 2025/26.

According to the Corporate Plan:

• Unprecedented demand meant that the number of new complaints rose by 39% in 2024/25, considerably more than the predicted 15% increase;
• Further increases of 12% are forecast for each year up to 2028/29; and
• Future developments in the pensions industry (such as small pot consolidation; default decumulation options; and pensions dashboards) are expected to impact the number of complaints received by TPO.

The Corporate Strategy explains TPO’s three year roadmap to address rising demand. It focuses on two strategic goals, as follows.

Providing an efficient, accessible and quality service, including through:

• Ensuring customers understand TPO’s role and can access TPO’s service at the right time;
• Proactively responding to developments in the pensions industry which may affect TPO’s work; and
• Smart and secure use of technology, including artificial intelligence (AI) for administration (but not decision-making).

Being an authoritative voice for improvement in the pensions industry, including through:

• Using TPO’s expertise to drive improvements in pension administration and handling of complaints;
• Improving member understanding of pensions administration and how to manage their complaints and queries; and
• Working with government and industry to increase understanding of developing opportunities and challenges in pensions.

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Authored by Jill Clucas.