UK pensions facing ‘pivotal’ moment as reform agenda accelerates

The UK pensions industry is facing a “pivotal time” as a wave of policy changes, regulatory developments and new initiatives reshape the landscape, according to Aviva wealth policy director, Emma Douglas.

Speaking at the Association of Member-Nominated Trustees (AMNT) Spring Conference 2026, Douglas, who has been endorsed by the Work and Pensions Committee (WPC) for the role of chair of The Pensions Regulator (TPR), said that the sector was currently navigating a "busy reform agenda", with "just so much going on".

She highlighted a wide range of developments affecting the industry, including the forthcoming Pension Schemes Bill, targeted support proposals from the Financial Conduct Authority (FCA), the newly established Pensions Commission, pensions dashboards, and ongoing work to expand collective defined contribution (CDC) arrangements.

Douglas also pointed to government initiatives aimed at increasing investment in private markets, such as the Mansion House Accord, alongside tax changes and salary sacrifice reforms that schemes and employers would need to implement in the coming years.

Douglas acknowledged that one of the most debated elements of the Pension Schemes Bill was Clause 40, which would give the government powers to direct pension scheme investment in certain assets if voluntary targets were not met.

“We’re all worried,” she stated. “No one likes the idea of the government controlling where members’ money is invested. It is definitely a threat to fiduciary duty.”

However, she noted that ministers had suggested the power would be used only as a backstop to ensure delivery of the Mansion House Accord commitments, which included a voluntary target for defined contribution (DC) providers to allocate 10 per cent of default funds to private markets, with five per cent invested in the UK.

Meanwhile, Douglas highlighted the introduction of the Value For Money Framework as a major reform to the DC market, arguing it could shift the industry’s focus away from cost alone.

“Value for money is a really big deal,” she said. “If we are genuinely to see a move from a focus on cost in the DC world to value, we have got to get this right.”

She suggested that trustees and providers would need to balance historic performance data and forward-looking assumptions when assessing default investment strategies, particularly as many schemes now incorporate private market allocations with limited track records.

Douglas added that the industry had called for a “soft launch” of the regime to ensure schemes have sufficient data and appropriate benchmarks before decisions are made.

Another key reform highlighted was the proposed introduction of default retirement income solutions, which would require schemes to provide members with a default way to take their savings as income in retirement.

However, Douglas warned that the proposed timetable could be difficult for trust-based schemes to meet.

“The deadline for trust-based schemes, 2027, next year, feels really unrealistic to me at the moment," she said.

She explained that designing suitable solutions would require trustees to analyse their membership, segment members into cohorts and determine which retirement income approaches may best suit each group.

Douglas also suggested that trustees may face challenges gathering the information needed to design appropriate solutions, as they typically lack detailed insight into members’ wider financial circumstances.

Looking ahead, Douglas stressed that the Pensions Commission's work could prove critical to addressing long-term challenges to retirement adequacy.

“I don’t think you can get to adequacy unless you are prepared to increase contributions,” she said, suggesting future recommendations could include a roadmap for higher auto-enrolment contributions.

She also indicated that the commission may revisit proposals to extend automatic enrolment to younger workers and remove the lower earnings threshold, although she acknowledged that such changes would increase costs for both employers and employees.

Douglas concluded that while the scale of reforms presents challenges, many of the initiatives - particularly around retirement income solutions - could improve outcomes for savers if implemented effectively.

“These defaults, how you spend your money in retirement, will probably be just about as important as how your default fund performs during the accumulation phase," she said.

“They are vital to get right.”



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