Public Service Pensions Update: April 2026

This month we cover three Local Government Pension Scheme (LGPS)-specific developments, seven updates relevant to all public service schemes, and two recent Pensions Ombudsman decisions on the status of administration standards and of general policies for the exercise of a discretion.

If you would like to discuss anything in this newsletter, please contact one of the experts listed at the end.

Focus on the LGPS

Pension Schemes Bill | Royal Assent expected

As reported in the last edition, the House of Lords made a number of changes to the LGPS pooling and governance provisions in the Pension Schemes Bill at report stage.

The bill subsequently had its third reading in the House of Lords and entered the final parliamentary stages. Following a period of "ping pong" (going back and forth between the House of Commons and House of Lords to reach agreement) the Bill is in final form and awaiting Royal Assent.

Of the main amendments to the LGPS provisions proposed in the House of Lords, the change to clause four (exemption from public procurement rules) is the only one to have survived ping pong.

The government whip's explanation of why the amendment to clause two of the bill (asset management) could "introduce, rather than mitigate, risks" that clause two could be used in unintended ways, and that the proposed new clauses on LGPS valuations and interim reviews of employer contribution rates are not needed as the underlying concerns will be addressed by other measures, can be found at Hansard column 566.

Access and fairness reforms | Bulletin and statutory guidance on survivor benefits

The Local Government Association (LGA) has published a detailed bulletin (number 276, 2026) providing "commentary for administering authorities in England and Wales on the changes introduced by the LGPS (Miscellaneous Amendments) (Member Benefits) Regulations 2026".

For each change, the LGA has set out the "relevant regulations, a description of what is changing and the impact of that change".

Among other things, the bulletin refers to the statutory guidance published by the Ministry of Housing, Communities and Local Government on 1 April to help administering authorities implement the updated survivor benefits, cohabitee and death grant rules in the regulations. 

Access and protection reforms | Regulations made 

The Local Government Pension Scheme (Amendment) (Elected Member Pensions) Regulations 2026 implement the reforms confirmed in the recent LGPS "scheme improvements (access and protection)" consultation response: granting access to the LGPS to eligible councillors, eligible mayors and certain related elected office‑holders and members in England.

The regulations also make changes "to ensure that allowances and other remuneration paid to elected office‑holders are treated consistently for pension purposes across the relevant authorities and bodies."

They will come into force on 11 May.

All schemes

McCloud remedy | Pensions Ombudsman signals new approach

The Pensions Ombudsman has shared a set of slides setting out the approach it will now take to complaints relating to the McCloud remedy and what it expects of schemes.

The ombudsman's position has moved on since its July 2022 information sheet on McCloud complaints as "milestones in the remedy process have now passed". It now intends to issue determinations on "cases concerning an issue or issues affecting several members across several schemes." These will set out its "position on key McCloud issues" and act as "guides and inform the approach schemes should take in resolving McCloud complaints internally."

Actions for schemes identified by the ombudsman include communicating with members on the steps being taken to implement the remedy; considering the approach to immediate detriment cases including any options for prioritising these; signposting members to internal dispute resolution procedures (IDRPs) and to the ombudsman on their completion; fully investigating and addressing complaints raised at IDRP, and looking out for significant determinations and updated information from the ombudsman.

Pensions dashboards | TPR updates guidance and calls for focus on value data and learnings

The Pensions Regulator (TPR) has published a market oversight report on pensions dashboards and updated its guidance for schemes. The market oversight report contains a number of learning points for all schemes.

The updates to TPR's guidance confirm good practice in certain areas following its oversight review. They highlight progress made by the Money and Pensions Service on the digital architecture and confirm some points TPR is often asked about. The checklist section has been updated to include two checklists: one for schemes yet to connect and one for schemes which have already connected.

The Pensions Management Institute has also published its  2026 Pensions Dashboards Guide.

Increase in the NMPA | HMRC confirms likely content of transitional regulations

HMRC's April 2026 pension schemes newsletter indicates what might be included in the transitional regulations to be made in connection with the increase in the normal minimum pension age (NMPA) from age 55 to 57 from 6 April 2028.

The NMPA is the lowest age at which a member in good health can access pension benefits without triggering the unauthorised payments rules. The law has already been changed to increase the NMPA from age 55 to 57 in April 2028 for most pension scheme members. The change does not apply to members of the "uniformed services pension schemes"; broadly, the armed forces, police and firefighters' schemes. Transitional regulations are needed to govern the position of people who reach age 55, but not age 57, before 6 April 2028.

Funds need to prepare for the increase in the NMPA. In another recent pension schemes newsletter, HMRC gave a reminder of possible actions in connection with the fact that some pension scheme members will retain a protected pension age of, usually, 55 after April 2028, and that this will usually survive a transfer.

Data protection | New complaints duties from 19 June: five steps schemes can take to comply

As reported in the previous edition administering authorities in their capacity as data controllers will need to meet new data protection complaints obligations by 19 June.

Osborne Clarke has published a separate Insight setting out more detail about the new requirements and identifying five steps pension scheme trustees (and administering authorities) can consider before 19 June.

Administration | Fraud minister urges trustees to 'take every opportunity' to protect members from fraudsters

The Pensions Regulator has shared the recording of the Pension Scams Action Group’s recent "Fighting Pension Fraud" webinar, during which the fraud minister urged schemes to familiarise themselves with the warning signs of pensions fraud, pointing to the TPR and City of London Police’s latest industry scam warning alert.

Schemes were encouraged to educate members by signposting them to PSAG’s Scam Safe leaflet  on protecting against pension scams and to the FCA’s Firmchecker tool and Stop!ThinkFraud, to tell Report Fraud about suspicious activity, and to sign up to the pledge to combat pension scams.

TUPE | Call for evidence and future reform

The government has launched a call for evidence on the Transfer of Undertakings (Protection of Employment) Regulations (TUPE). Its stated aims are to strengthen protections for employees going through TUPE transfers and to modernise the regulations to improve efficiency.

The call for evidence includes a request for respondents to comment on whether they agree or disagree that employee pension rights are sufficiently protected under a TUPE transfer.

A summary by Osborne Clarke's employment team's summary is available here.

King's Speech | What might happen before and after 13 May

The state opening of Parliament and the 2026 King’s Speech are scheduled to take place on 13 May. The King will open Parliament and set out the government's proposed legislation for the new parliamentary session.

The Pension Schemes Bill is expected to receive Royal Assent before the current session of Parliament is prorogued.

A recent House of Commons library briefing paper gives more detail and suggests areas of reform which might be picked up in bills to be announced in the King's Speech. These include a new system of local government standards in England, measures "to strengthen the accountability of mayoral strategic authorities", and further public procurement reform.

The Pensions Ombudsman  | Administration standards and discretion policies

The Pensions Ombudsman has considered whether there is any strict legal requirement for an LGPS administering authority to meet the time frames contained in a Pension Administration Strategy (PAS), or whether missing a timeframe set out in a PAS can give rise to a claim on other grounds.

The ombudsman's analysis offers useful guidance for any administering authority considering a claim that a timeframe in a PAS has been missed. (CAS-92644-J5C3)

The ombudsman has also confirmed that, while "it is reasonable to have a general policy for the exercise of a discretion" (in this case, a general policy not to exercise the discretion to agree an extension of the three year time limit for making an application to review whether a member meets the tier two ill-health condition in the NHS Pension Scheme where a request is made after the deadline has expired) "it is still incumbent on decision makers to consider that discretion in light of the facts of each case and/or an individual’s specific circumstances." (CAS-82907-M1J5)

House of Commons Library | New and updated briefing papers

Recent House of Commons Library briefing papers of interest include:

• Inheritance tax: a basic guide
• Public service pension increases
• Nature based solutions for climate change
• NHS pay and pensions
• Pensions tax and Pensions tax relief
• Pensions in the UK (including the state pension)
• Taxation of state pension.

This newsletter covers developments relating to public service pensions in England and Wales with a focus on the Local Government Pension Scheme.