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Pensions Bulletin 2025/15

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Video - Podcast
Translations from English are done by AI, without human oversight, and may not be accurate
Pensions & benefits Climate change Pensions dashboards Policy & regulation

This edition: Pensions Regulator publishes climate adaptation report, Pensions Regulator uses AI to detect scam sites, Pensions Regulator issues pension saver videos to push schemes to get dashboard ready, and more.

Mountain topped with snow

Pensions Regulator publishes climate adaptation report 

The Pensions Regulator has published its 2025 climate adaptation report, required under the Climate Change Act 2008. The report covers the risks from climate change that are most relevant to trust based occupational pension schemes, the policies and practices to address them and progress since the last report in October 2021 (see Pensions Bulletin 2021/46). 

This latest report is the contribution of the Pensions Regulator to the national assessment of the UK’s resilience to climate change and supports the UK’s Third National Adaptation Programme.

Introducing the report, Nausicaa Delfas Chief Executive at the Pensions Regulator, says that the Regulator will continue to: 

  • educate and support trustees, questioning their decisions where appropriate; 
  • enforce against trustees of schemes failing to meet statutory duties relating to climate change and ESG; 
  • encourage trustees of schemes in scope to go beyond the regulatory minimum and build their capacity in managing climate change and wider sustainability risks; and 
  • work with government, regulators and industry on initiatives to improve industry’s management of climate and ESG risks. 

In the accompanying press release, the Regulator singles out (again) small DC schemes, calling on recent survey data to support its view that there are too many small DC schemes where trustees' knowledge of the scale of financial risks posed by climate change is limited. As a result, the Regulator calls (again) on those trustees to upskill or consider consolidating in savers’ interests.

Comment

This report is essentially to fulfil a compliance requirement from the 2008 Act and as such there is no particular action needed by the pensions industry. But it has given the Regulator a platform on which it has set out its assessment of the current state of industry practice on climate change and what else it intends to do in this space, which is worth noting.

One point of note is that in its Climate Change Strategy 2021 published in April 2021 (see Pensions Bulletin 2021/15) the Regulator said, amongst other things, that it would carry out a thematic review on scheme resilience to climate-related scenarios to help identify the extent of risk from climate change. The report mentions this review, but there is no further news on whether it will in fact be carried out.

Pensions Regulator uses AI to detect scam sites

The Pensions Regulator has announced that, along with the Pension Scams Action Group, it has developed an AI tool to detect scam websites and to date has reviewed 830 websites, taken down 29 high-risk sites and made 94 referrals to partner agencies. The Regulator notes that pension scams are frequently facilitated by scam websites.

There is also mention of a new Fraud and Cyber Crime Reporting and Analytics Service that will replace Action Fraud when it is launched later this year. This new service will “result in fundamental service improvements to how intelligence is gathered nationally from multiple sources and speed up the analysis of reports, and how quickly they are sent to police forces for investigation”.

The Regulator also calls on schemes to continue to report scams to Action Fraud until the replacement service is launched, as it is concerned that recent survey data show only 11% of DB and DC schemes are currently reporting scams to Action Fraud.

In a separate development, the Fraud Compensation Fund has published some tips for individuals to help them spot fraudulent communications. This comes after it has recently been made aware of a scam where some scheme members are being sent fraudulent letters, claiming to be from the Fund, asking them to claim their Fraud Compensation Fund payments.

Comment

It is good to see that technology is being used to detect scam websites, but it is not clear over what period this has been running and how quickly such websites can be taken down. There is also the worry that, given the nature of scams, this latest activity may still, like many previous initiatives against scams, be akin to whack-a-mole.  

Pensions Regulator issues pension saver videos to push schemes to get dashboard ready  

The Pensions Regulator has announced the publication of four short YouTube videos, in which pensions savers emphasise that having information about their pensions in one place could make a significant difference to their retirement planning. It is sharing these videos on its social media channels and with industry stakeholders as it is concerned that the pensions industry, taken as a whole, has not made sufficient preparations for pensions dashboards. 

The Regulator points to its tracker survey published in March 2025, saying that while eight in 10 schemes say they are on track to connect in line with dashboards on time, one in four still hold some form of non-digital dashboard data, and many schemes hold out of date information on the value of savers’ pensions. 

The Regulator says that all 2,700 schemes with dashboard obligations have a date to connect to the system, with the first batch connecting in April 2025 and all having to connect by October 2026. It goes on to say that it is supporting schemes in preparing for their dashboard duties through regular communications, awareness campaigns and engagement and later this year it will be engaging with schemes to understand in more depth the quality of their data. 

Comment

We can expect a lot more broadcasting from the Regulator on matters such as this over the coming months as it seeks to get as many of the 2,700 schemes as possible connected and capable of supplying full information by their respective deadlines.  

PRAG examines Virgin Media impact on pension scheme accounts 

The Pensions Research Accountants Group has issued to its members a discussion paper outlining its understanding as to how the FRS 102 contingent liability disclosure requirement and the 2018 Pensions SORP may need to be applied, in relation to the Virgin Media case, for pension scheme accounts. This is a separate matter to the potential impact on sponsor accounts on which the Institute of Chartered Accountants in England and Wales recently issued a note of considerations (see Pensions Bulletin 2025/07). 

After the necessary introductions the discussion paper looks at three scenarios – where no disclosure is required, where a narrative contingent liability disclosure is necessary and where a financial provision in the scheme’s financial statements is the appropriate way forward. 

PRAG’s discussion paper concludes with seven questions on which it would like its members’ assistance, before it issues any formal guidance. Feedback is requested by 9 May 2025 and PRAG initially intends to collate views for a report at its summer meeting.

Comment

PRAG has not indicated any timescale to which it is working on possible formal guidance for pension scheme auditors, but as things currently stand it seems unlikely that any guidance will be available in time for when 31 March 2025 year-end pension scheme accounts need to be signed off. Nevertheless, the existence of this discussion paper may influence how pension scheme auditors now approach the Virgin Media issue. 

PASA updates buy-in and buyout data readiness guidance 

The Pensions Administration Standards Association has announced the release of an updated and expanded version of its guidance on data readiness for buy-ins and buyouts. This guidance should be read in conjunction with that issued in February 2023 (see Pensions Bulletin 2023/08) which it appears is not being withdrawn.

The original guidance covered a number of critical areas, including key data items, the consequences of holding incomplete and poor-quality data and actions which should be taken to demonstrate good governance and ‘quick-wins’. It concluded with the thought that good planning leads to certainty and preferential pricing. 

PASA says that the 2025 guidance offers deeper insight into the data elements insurers typically consider critical for ensuring a smooth and successful transaction. PASA also says that as the guidance can’t cover every unique circumstance those responsible for managing data strategies should always consider scheme-specific needs and work closely with professional advisers to tailor plans accordingly

Comment

This latest guidance is particularly noteworthy for the tabulation of the key data items schemes are expected to hold electronically – for all members and the most common membership statuses. Those responsible for delivering data readiness may wish to compare the PASA tabulations against their own lists.    

PPF panel appointments announced 

The Pension Protection Fund has announced the latest appointments to its Trustee Services Panel and for its new Restructuring and Pre-Insolvency Services (RPIS) Framework. 

Four providers are named as continuing to provide trustee services for both underfunded and overfunded schemes during the assessment period, as part of the PPF’s Trustee Services Panel. 

Eleven providers, including LCP, are named for the RPIS Framework which aims to support stressed schemes at the pre-insolvency stage. 

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