Introduction
The most significant development this quarter is arguably the Government's updated roadmap, which provides a fresh indication of when the various reforms under the Pension Schemes Act 2026 and beyond are likely to take effect.
For DB schemes, the major reform is "surplus sharing". Here the Government is ahead of schedule. Soon after the new Act was passed, it published draft regulations and a consultation on the conditions for refunds from ongoing schemes, with implementation planned for April 2027, several months sooner than originally proposed. Within the consultation, there are few surprises. As expected, the proposed funding test is based on low-dependency rather than buy-out funding, albeit with a forward-looking element.