Policy paper

Workplace pensions: an updated roadmap

Updated 14 July 2026

This was published under the 2024 to 2026 Starmer Labour government

Applies to England, Scotland and Wales

Ministerial Foreword

The existence of a period of leisure after a lifetime of work is what human progress looks like. That is why we should always celebrate one of the biggest wins of the 20th century: for the first time in history, retirement as a realistic prospect for the vast majority of ordinary workers. The task facing us now is to secure that progress for the 21st century. We must do so in the face of change and of challenges, not least the reality that we are an ageing society and projections that on current trends those retiring in 2050 will have lower private pension incomes than those retiring today.

That is why pensions matter. To those saving into them, and to Britain. And it is why pension reform is such a central feature of this government’s agenda. That agenda has already seen us legislate, with the Pension Schemes Act receiving Royal Assent on 29 April 2026. This lays our major planks of reform, setting us on course for a landscape of bigger and better pension schemes, focused on driving up the outcomes for workers savings, and able to invest in a wider range of assets. It also addresses some well-known challenges, tackling the proliferation of small pension pots and introducing default pensions, so savers aren’t left facing hugely complex financial decisions to turn their pension pot into a secure retirement income. 

The Act also helps adjust to significant change for defined benefit (DB) pensions: a shift for the system as a whole, even if sadly not every pension scheme, into surplus. That opens up a wider range of options for trustees, with the Act enabling the safe sharing of surpluses, a permanent Superfunds regime and a zero Pension Protection Fund levy.  

There is more to come. Our changing pensions landscape, not least the prospect of such significant pension schemes in future, also requires us to strengthen trusteeship and governance. And since the Pension Schemes Act received Royal Assent, the Pensions Commission have published their interim report, setting out the problem statement for the next phase of reform: too many people are not saving enough for later life and plenty not saving at all with virtually no pension saving being done by the wholly self-employed. I look forward to receiving their final report early next year and we will swiftly turn their recommendations into action. 

This is a hugely necessary reform agenda, and one that is now very much entering its delivery phase spanning government, regulators and industry. The scale of change also raises the stakes for it being implemented well. The single biggest case for optimism about our collective ability to do so comes from the breadth of the consensus that stands behind these reforms – across parties, policy makers and the industry as a whole. The sequencing of change is also crucial, recognising both capacity constraints on organisations and the interaction of different elements of reform. 

This is why I have committed to issuing and updating this roadmap. It means everyone can see how we anticipate the next phase of the reform programme evolving, rightly responding to the calls from industry for more certainty. It takes a pragmatic approach, reflecting on valuable engagement right across the industry, for example updating delivery plans for the new Value for Money (VfM) regime and ensuring the timeline for Guided Retirements works alongside legislation to enable Retirement Collective Defined Contribution (R-CDC).  

This roadmap recognises both the imperative for change and the reality of what it takes to bring the reforms to life. It charts the course to a pensions system fit for the 21st century, with pension savers at its heart. We all know there is much to be done, but holding us to the course laid out in this roadmap is something even more important: the scale of the prize for doing it.

Torsten Bell MP, Minister for Pensions

About this document  

This document sets out the government’s updated pensions roadmap, bringing together the programme of pensions reforms, particularly those enabled by the Pensions Schemes Act 2026 into a clear and sequenced plan for delivery. 

This document updates the timelines published in June 2025 and outlines the detailed phased implementation of measures across the reform programme, and their interaction and the ultimate outcomes we want to achieve in DB, defined contribution (DC) and collective defined contribution markets. 

This document should be read alongside relevant legislation, consultations and supporting publications linked to the Pensions Schemes Act 2026 and the wider programme of pensions reform. It can also be read alongside the earlier version of the government pensions roadmap.

Updated roadmap

Introduction  

1. We are publishing the updated version of the pension reform roadmap, consistent with the government commitment to spell out the phased implementation of the reforms. This builds on the timelines provided in June 2025, following Royal Assent of the Pension Schemes Act 2026. These reforms will combine to deliver greater retirement outcomes for savers and should be seen as a comprehensive reform agenda to ensure that today’s workers can look forward to a comfortable retirement tomorrow. 

2. These reforms are intended to ensure savers get better value from the contributions that they put into their pension pot through the VfM framework, while providing them with a default pension at retirement through the implementation of the Guided Retirement framework. An R-CDC regime will provide for an additional retirement product option. We want savers to get the most out of their money, and ensure the market is working in their best interests, building the strong foundations ahead of the Pensions Commission recommendations.  

3. We are working closely with The Pensions Regulator (TPR), the Financial Conduct Authority (FCA) and HM Treasury (HMT), as well as with the Money and Pensions Service (MaPS) on associated guidance, through the process of implementing these reforms. This roadmap is intended to signal as many of the implementation steps as possible.  

Ensuring the market is set up to deliver for savers  

4. The Scale measures along with the Contractual Override and VfM measures will reshape the DC market. The measures will reduce the fragmentation within DC schemes and support the government’s vision of good value, scale pension provision for the mass-market. The Scale provisions will require all DC multi-employer schemes which are used for automatic enrolment (AE) to have assets of at least £25 billion in a single main scale default arrangement. This includes Master Trusts (MTs), Group Personal Pensions and apply to any workplace DC scheme that is offered to more than one employer to meet their AE duties.   

5. The Scale thresholds will be introduced in April 2030. In advance of that, we expect applications for Scale and the transition pathway to be made from 2029. To ensure continuity of saving for members, those schemes that are not approved at scale or for transition pathway relief will enter a protected period during which they can continue to manage their existing business. This ensures that ongoing contributions can continue from existing employers whilst schemes work with regulators and employers to move all future contributions to a different scheme. We expect to consult on regulations in the latter part of 2027 with consultations by regulators on TPR Code and FCA guidance to follow during 2028. 

6. This timing provides clarity and certainty, balancing the need for timely decision making with the pre-requisite to ensure that the assumptions used in applications are finalised and robust.   

7. We will publish more detail on the Fragmentation Review well in advance of the review commencing. The date indicated in the roadmap is the final date for all Scale measures to be switched on.     

8. We are also launching our joint consultation on the VfM draft regulations and FCA rules, and responding to the last consultation held in early 2026. This is the latest in a series of consultations on the VfM framework.  

9. Through extensive engagement and the passage of the Pensions Schemes Act 2026, we have been clear that the first VfM assessments will be in 2028, based on 2027 data. VfM is a central pillar of our reform package, with other measures dependent on the implementation of the framework.  

10. To ensure that we appropriately manage the market impact of this major reform, and in response to industry feedback, we believe that a phased implementation of the framework is appropriate.  

11. As such, only larger schemes such as MTs, large Single Employer Trusts^{[footnote 1]} and firm-designed (non-bespoke) multi-employer contract-based arrangements open to new employers will be required to complete VfM assessments in 2028, the first year of the framework. We will also not apply automatic consequences on the basis of the outcomes of assessments in that first year.  

12. In the first year of VfM, smaller schemes will only be required to complete data returns but will not be required to complete assessments, and their data will not be published. This means these schemes will not be required to complete full VfM assessments until 2029. More information on the phased implementation is available in the VfM draft regulations and rules consultation.

13. The Contractual Override provisions will be key in supporting the implementation of the VfM Framework and the government’s wider Scale and Consolidation agenda. Providers will be able to use the Contractual Override mechanism to transfer members from contract-based pension arrangements which are found not to be providing value to those that are, and will enable them to consolidate the large number of arrangements that exist in the market today. The provision will establish broad equivalence with the trust-based market where an equivalent power is already available and drive better outcomes for members. The implementation of the Contractual Override mechanism is on track for Spring 2028, being timed in conjunction with the VfM Framework as the consistent and comparable data produced as part of VfM can be used as the basis for the best interests test that providers will need to meet, to show that any use of the Contractual Override provisions will lead to a better outcome for members.  

14. We are continuing to work through the interaction between Scale, VfM and Contractual Override, and the plans set out in the roadmap are our best estimate at this point in time.  

15. Alongside this programme of reforms, we are developing guidance on trustees’ fiduciary duties related to investment decision-making. This will provide clarity and practical support, giving trustees confidence to act in the best interests of members, including over the long term. The guidance will be developed in close collaboration with regulators and industry, with consultation planned for summer 2026.

Guided Retirement, Default Pensions and decision-making

16. The Guided Retirement framework will ensure the vast majority of people are offered default pensions which are designed to provide a sustainable pension income, without the individual needing to make complex decisions while always retaining their right to do so.    

17. Pension schemes are considering a range of default pensions, including ‘flex and fix’ and R-CDC. Guided Retirement and R-CDC timelines are therefore interrelated, and we are conscious that R-CDC schemes may need time to prepare their application following the coming into force of R-CDC legislation, and a period of preparation to become operational following authorisation. To support the development of R-CDC, we will consider allowing schemes who are committed to pursuing an R-CDC scheme as a default pension, a targeted and time-limited extension to allow the scheme to become operational, before beginning to default members into it. We will test a proposal for an extension mechanism at consultation in the autumn.  The R-CDC market is new and innovative and will take time to develop. We want to support that innovation.

18. The timeline for implementing the Guided Retirement framework now includes a planned Industry Delivery Group and Member Interests Group, enabling us to consult on more thorough and considered policy proposals in autumn 2026. 

19. The FCA will be publishing a discussion paper on introducing equivalent requirements for contract-based workplace schemes, to align with the Guided Retirement framework policy consultation and R-CDC regulations consultation.  

20. The Department for Work and Pensions (DWP) is working closely with the Financial Reporting Council (FRC) to explore the development of standardised approaches to pension illustrations, including for common forms of decumulation and for individuals in decumulation. These approaches would support clear and consistent communication of expected retirement income for default pensions. The inclusion of FRC milestones within the roadmap reflects this joint work and the importance of illustration standards in underpinning the delivery of Guided Retirement. 

21. The Guided Retirement framework will reduce the risk of bad outcomes for savers who do not wish to actively engage. Alongside that, for those savers who wish to engage and make decisions about their pensions, we are putting in place a number of supportive measures. We are working closely with MaPS to ensure that their guidance appropriately reflects the changes Guided Retirement for DC pension products and R-CDC will implement. Supporting guidance will help savers understand their options (including, but not limited to, Default Pension flex and fix models and R-CDC). The Stronger Nudge to Pension Guidance trigger point will also remain in place – schemes offer to book members a Pension Wise appointment when they apply to access their benefits, unless they opt out. In addition, Pensions Dashboards will help savers with their retirement planning, with appropriate guidance and information in place to support decision-making. 

22. Targeted Support is also an integral part of this reform agenda. DWP are working closely with the FCA to ensure Default Pensions and Targeted Support provisions complement each other. The government’s aim is for DC savers to benefit from a simpler process and less risky decision-making as they approach retirement. The introduction of Default Pensions will mean DC pension savers will not need to make complex decisions to realise their benefits. Targeted Support will help individuals by providing actionable suggestions so they feel confident to make their own choices. The government is seeking to ensure that all pension members are offered good quality support to manage their pensions, regardless of how their pension provider is regulated. 

23. The government has carefully considered how Targeted Support interacts with the Privacy and Electronic Communications Regulations to strike the right balance between protecting consumers’ marketing preferences and privacy rights, while ensuring people can access support which could help them. The FCA and Information Commissioner’s Office published a statement in December which sets out how firms can engage their customers about Targeted Support. We have also committed to taking forward secondary legislation to enable workplace pension providers to send targeted support to members who have not opted out of direct marketing, reflecting the fewer opportunities members have to provide marketing consent through AE.  

24. FCA firms with appropriate permissions can also provide regulated financial advice, which can include simplified forms of advice, or more commonly comprehensive financial advice, which takes into account the overall circumstances of an individual.  

Consolidating Small Pots 

25. Following the Pensions UK Small Pots Digital Systems Feasibility Review, published in September 2025, we have commenced a subsequent phase of work to build on its findings and recommendations. This includes undertaking our own detailed review to inform final decisions on the digital infrastructure required to support the Small Pots consolidation framework. These decisions will be subject to consultation.  

26. This roadmap therefore includes indicative delivery timelines for Small Pots consolidation. These timelines remain subject to change pending final decisions on the delivery approach. We will publish a more definitive timetable when we consult on next steps in the autumn. This first phase of consultation will focus on exploring the framework for establishing default consolidator schemes, alongside further consideration of the underpinning infrastructure required to support pension pot consolidation. It will also examine the appropriate eligibility criteria and potential exemptions within the system. The role and responsibilities of ceding schemes will be considered in a subsequent phase of consultation. 

Defined Benefit roadmap 

27. A number of the changes brought forward within the Pension Schemes Act are already in place and benefitting Defined Benefit (DB) pension schemes, their sponsoring employers and members. New legislation provides a clear and pragmatic route forward for schemes affected by the Court of Appeal’s ruling in Virgin Media v NTL (National Transcommunications Limited) Pension Trustees, to show how historic benefit changes met the necessary standards. The new legislation provides schemes with much needed certainty around the process and next steps. Additionally, changes to the pension protection levy mean that traditional schemes, and their sponsoring employers, are no longer paying this levy. The Pension Protection Fund (PPF) administration levy has been abolished for all schemes.

28. We are continuing to work at pace with TPR on the implementation of the Surplus and Superfunds regulations.   

29. DB Surplus will enable more trustees of well-funded occupational DB pension schemes the flexibility to share surplus funds with the sponsoring employer and benefit members, subject to safeguards that protect members’ pensions. Regulations will set out the conditions that trustees must meet before surplus can be released. The consultation on The Occupational Pension Schemes (Payments to Employer) Regulations 2027 has launched and will close on 2 September 2026.   

30. In the Autumn Budget 2025, the Chancellor announced changes to tax legislation that will allow direct surplus payments to members to be treated as authorised payments for tax purposes. The government will separately carry out a technical consultation on those tax changes in the summer. The government intends to provide further detail on changes to tax legislation for the treatment of direct payments to members in the Finance Bill 2026 to 2027. Subject to Parliamentary approval, the legislation is expected to come into force from 6 April 2027. This alignment will support a coherent and effective implementation of the Surplus regime.

31. The industry and schemes are asking for certainty around the Surplus regime so that trustees can make choices on their schemes. The Surplus regulations are expected to be made early in the new year and come into force on the 6 April 2027, alongside the tax changes, reflecting our intention to bring forward the full package of reforms together, ahead of the timeline within the earlier roadmap. We are working closely with TPR and the FRC to ensure all supporting elements are aligned, including further guidance which TPR plan to consult on, so that, taken together, this provides a clear and coherent framework to support trustees in making informed decisions.

32. On Superfunds, we intend to consult on the regulations early next year prior to the implementation of the permanent regime. The Superfund market is evolving and the Act provides potential providers with greater regulatory clarity as alternative models, including those looking to share future surplus with members that are looking to enter the market. Alongside Superfund developments, we are also seeing innovation in the wider DB market. Whilst we anticipate the full regime will come into force in 2028 as set out in the previous roadmap, allowing more time before consulting on the draft regulations and implementing the regime later in 2028 creates more space to learn from TPR’s interim regime and react to market changes. This will help ensure members are protected and the legislation works as intended in a way that reflects market developments. 

33. Within the Pension Schemes Act, we introduced legislation that provides for indexation of compensation payments from the PPF and Financial Assistance Scheme (FAS) that relate to pensions built up before 6 April 1997. These will be Consumer Prices Index (CPI)-linked (capped at 2.5%) and apply prospectively (to payments going forward) for members whose former schemes provided for these increases. 

34. Eligible DB schemes outside of the PPF are also impacted by this change. The introduction of pre-97 indexation will affect the PPF liabilities for DB schemes that provided for pre-97 indexation. We are therefore working with PPF to deliver the PPF/FAS pre-97 indexation regulations which contain some transitional arrangements and make a number of technical changes to the legislation. A targeted consultation on these measures with key stakeholders will take place over the summer to ensure that the legislation works as intended. The first payments to eligible PPF/FAS pre-97 core members will be made in January 2027.   

35. Legislative changes have given the PPF Board greater flexibility to adjust the annual pension protection levy that it collects from conventional DB schemes. Restrictions in the legislation have been removed so that the PPF Board can reduce the levy right down to zero and then raise it again within a reasonable timescale, if that becomes necessary. The PPF Board has announced a zero levy for conventional defined benefit schemes for the 2026 to 2027 financial year.  However, the PPF Board will continue to collect a levy from schemes that it considered that pose a risk such as schemes without substantive employer covenant.

36. To enable PPF and FAS members diagnosed with a terminal illness to receive a payment at an earlier stage of their illness, the Pension Schemes Act extended the definition of life expectancy from 6 months to 12 months from end of life.  

Looking to the future  

37. As we move into the delivery phase of our pensions reform agenda, we are also looking ahead the next phase. We want to extend VfM to pensions in the decumulation phase in due course but need to ensure that VfM is working effectively, as well as develop sound proposals for Guided Retirement. The priority would be ensuring default pensions used for Guided Retirement purposes provide fair value, as they are likely to be made available to the majority of savers. Other products not used for AE purposes are used by an arguably more engaged group of savers and therefore, are better able to choose products that meet their needs.  

38. We are also considering feedback received in response to the ‘Trust-based pension schemes: trusteeship and governance, building a stronger future’^{[footnote 2]} consultation and will publish our response in due course, setting out next steps for that work.

39. As before, these measures will complement other measures such as Pensions Dashboards and work on non-advised DC transfers to help ensure the pensions eco-system supports positive member outcomes. We recognise there is more to do. The reforms we are putting in place means pensions regulation also needs to evolve so that it provides the right governance, deals with risks in a consolidated market and gets a durable framework in place that strengthens trust and confidence in the system. 

40. This package represents an ambitious set of reforms, necessarily so to put the saver first and help ensure they get better value and more secure retirements. The roadmap charts the direction and provides indicative timelines, representing our best estimates, with sufficient specificity to support good business planning.  

41. Alongside this, the Pensions Commission is expected to report in early 2027. This complements the government’s workplace pensions market reforms through looking at how we can ensure adequate outcomes for the longer term.

DC and CDC roadmap

Between January and March 2026 

• VfM: TPR and FCA Policy Consultation

Between April and June 2026 

• GR: Delivery Group commences

Between July and September 2026 

• VfM: consultation on DWP draft regulations and FCA rules published

• VfM: TPR additional guidance published

• CDC: regulations to enable unconnected multi-employer schemes come into force 31 July

• Fiduciary Duty and investment decision making: guidance consultation published

• Small Pots: DWP policy consultation - Building the Foundations for Consolidation published

Between October 2026 and December 2026 

• R-CDC: draft regulations consultation published

• GR: DWP policy consultation and FCA discussion paper published

• Contractual Override: HMT Regulations laid

Between January 2027 and March 2027 

• Fiduciary Duty and investment decision making: guidance published

• VfM: DWP Regulations come into force and FCA policy statement published in Q1

• Contractual Override: FCA consultation on draft rules published

• VfM: TPR Code consultation published

Between April 2027 and June 2027 

• Small Pots: DWP publishes government response and draft regulations consultation – Building the Foundations for Consolidation (tranche 1)

• Scale: report on the effects of consolidation on pension schemes published

• Small Pots: TPR code consultation/FCA rules consultation

Between July 2027 and September 2027 

• Contractual Override: FCA policy statement published

• GR: DWP consultation on draft regs and FCA consultation on draft rules

Between October 2027 and December 2027 

• Scale: DWP regulations consultation published in autumn/winter 2027

• R-CDC: regulations laid and TPR consult on changes to code

• Small Pots: DWP publish policy consultation – further consolidation considerations (tranche 2)

Between January 2028 and March 2028 

• Small Pots: DWP government response to regs consultation and lay draft regulations and Parliamentary process for tranche 1

• Scale: consultations by regulators on code and guidance during 2028 

• Contractual Override enabled March 2028 

• VfM: TPR Code in force and schemes submit first data to regulators in March

• Small Pots: FCA policy statement published

Between April 2028 and June 2028 

• GR: TPR Guidance consultation published (dependent on regs)

• Small Pots: DWP publish government response and draft regulations – further consolidation considerations (tranche 2)

Between July 2028 and September 2028 

• GR: regulations made and FCA policy statement published

• GR: publications of FRC’s standards for illustrations for common forms of decumulation options (including R-CDC) plus illustrations during the decumulation phase

Between October 2028 and December 2028 

• VfM: first assessment reports and relevant data published in October

• R-CDC: legislation and code come into force and applications for authorisation begin

• Scale: regulations made; applications and assessment periods commence during 2029

Between January 2029 and March 2029 

• Scale: Fragmentation Review commences and requirements for new default arrangements to be approved during 2029

• Small Pots: lay draft regulations and Parliamentary process for tranche 2

• VfM: schemes submit second year data

Between April 2029 and June 2029 

• R-CDC: estimated date for first R-CDC schemes to be authorised

Between July 2029 and September 2029 

• GR: MTs and FCA regulation workplace schemes compliant

Between October 2029 and December 2029 

• VfM: second year assessment reports and data published

Between January 2030 and March 2030 

• Scale: Fragmentation Review report published during 2030

Between April 2030 and June 2030 

• Small Pots: consolidation begins

• Scale: scale threshold and transition pathway commenced

Between July 2030 and September 2030 

• GR: SETs compliant

• GR: schemes with R-CDC default pensions compliant

By end of 2035 

• Scale: transition pathway ends. All GPPs and MTs to have at least £25 billion

DB roadmap

Between January and April 2026 

• PPF Administration levy: abolished

Between April and July 2026 

• Surplus: DWP draft regulations consultation published

• PPF/FAS Pre-97 indexation: stakeholder engagement on draft regulations

• PPF Levy: regulations commence 29 June

• PPF/FAS Terminal Illness: definition changes to 12 months’ life expectancy

Between October 2026 and January 2027 

• Surplus: DWP consultation response published and TPR guidance consultation published

• PPF/FAS Pre-97 indexation: Pre-97 indexation regulations come into force and first payments made in January 2027 for core PPF/FAS members

Between January 2027 and April 2027 

• Superfunds: DWP draft regulations consultation published

Between April 2027 and July 2027 

• Surplus: DWP regulations come into force, HMRC direct payments regime comes into force and TPR consultation response and guidance, and FRC technical actuarial guidance on payment of surplus published

Between January 2028 to October 2028 

• Superfunds: TPR code consultation published 

• Superfunds: DWP regulations and TPR code comes into force

1. In this context, we propose that ‘large’ would mean 50,000 members (both active and deferred) or more. ↩

2. Trust-based pension schemes: Trustees and governance, building a stronger future - GOV.UK ↩