The Pensions Brief: March 2026

Why It Matters

Non‑compliance with the new complaints framework exposes schemes to regulatory sanctions and reputational risk, while the dashboard and levy updates influence funding strategies and transparency expectations across the pension industry.

Key Takeaways

• Data Act complaints process required by 19 June 2026
• ICO guidance adds design, default, and access request rules
• Pension dashboards FAQs clarify reporting standards and data‑matching
• PPF zero levy applies to conventional DB schemes 2026/27

Pulse Analysis

The Data (Use and Access) Act 2025 introduces a mandatory complaints‑handling framework that becomes enforceable on 19 June 2026. Trustees and scheme administrators must provide a clear submission channel, acknowledge complaints within 30 days, investigate promptly, and communicate outcomes without undue delay. The Information Commissioner’s Office has issued detailed guidance, extending to data‑by‑design principles and subject‑access requests, to help organisations align their processes with the new legal expectations. Failure to comply could trigger regulatory enforcement, reputational damage, and potential financial penalties, making early implementation a strategic priority.

Parallel to data compliance, the Pension Dashboards Programme has released a suite of FAQs that demystify the emerging reporting standards and outline the consultation process for proposed revisions. The guidance, complemented by PASA’s recent webinar Q&A on data‑matching tools, equips trustees with practical insights for aligning scheme data with the dashboard ecosystem. While no immediate regulatory action is required, adopting these best‑practice recommendations can enhance transparency, improve member confidence, and position schemes favorably as the UK moves toward a unified pension information architecture.

The Pension Protection Fund’s decision to levy zero contributions for conventional defined‑benefit schemes in the 2026/27 financial year reflects a broader policy shift aimed at easing funding pressures on legacy plans. However, the continuation of levies on alternative covenant structures, such as DB superfunds, signals that risk‑based pricing remains central to the Fund’s sustainability model. Combined with PASA’s final digital‑transformation guidance, which stresses iterative improvement and member engagement, scheme trustees now face a convergence of regulatory, financial, and technology imperatives that will shape pension governance over the next decade.