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ARTICLE · 13 NOVEMBER 2025

Pensions Planner - Winter 2025

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

Herbert Smith Freehills Kramer LLP

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Steady progress for the Pension Schemes Bill in the House of Commons. Committee stage was completed ahead of schedule.

United StatesEmployment and HR
Samantha Brown
Samantha Brown
Rachel Pinto
Rachel Pinto
Michael Aherne
Michael Aherne
Richard Evans
Richard Evans
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Introduction

Steady progress for the Pension Schemes Bill in the House of Commons. Committee stage was completed ahead of schedule. And even the most controversial provisions of the Bill emerged intact, with Pensions Minister Torsten Bell later urging the industry to "chillax" about measures to allow mandation.

The big change to the Bill so far has been the addition of Virgin Media provisions. Two years on from the initial High Court ruling, DB trustees and sponsors now have a clear idea about how historic uncertainties can be resolved. Guidance has been promised, to support actuaries in providing retrospective confirmation.

While the Bill's framework is taking shape, much of the underlying detail remains unclear. For DB schemes, the main question concerns the funding test which will apply for surplus refunds. The Government said in May 2025 that it was "minded to" prescribe a low-dependency test, but encountered some resistance. Proposals are expected shortly.

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