Three pensions consultations close in the first week of September, and TPR’s new Regulatory Roadmap now dates the rest. The regulator published its five-year Corporate Strategy on 14 July alongside an AI plan for trustees. Separately, PwC research puts meaningful barriers to full automation across 80 per cent of legal work.
TPR publishes a five-year strategy and a regulatory roadmap
TPR published its Corporate Strategy 2026-31, Corporate Plan 2026-27 and a Regulatory Roadmap on 14 July 2026 (PN26-15). Six outcomes drive the strategy: savings are secure, better value, pensions are fair, well-run schemes, a sustainable and resilient market, and a seamless and integrated system.
The Roadmap is the practically useful document. It sets out when TPR, the DWP and the FCA will engage on pensions reform through consultations, regulation and guidance. Milestones cover value for money, guided retirement, collective defined contribution schemes and defined benefit surplus release. TPR describes the intent as a no surprises approach. The programme splits into an enable phase across 2026 and 2027, implementation in 2027 and 2028, and an embed and scale period to 2030. TPR flags the timings as indicative.
Chief executive Nausicaa Delfas called it a significant departure from the previous strategy, which centred on accumulation. The context TPR gives is 23 million people saving into a workplace pension and 15 million working-age people still under-saving. The full suite is on TPR’s site.
Which pensions consultations close in September?
Three, within a week of each other. The DWP consultation on the draft Occupational Pension Schemes (Payments to Employer) Regulations 2027 closes at 11:59pm on 2 September 2026. It sets the conditions for releasing DB surplus to employers. HMRC’s draft legislation on authorised member surplus payments takes feedback until 7 September. The Value for Money framework consultation also closes on 7 September.
The substance of the DWP proposal is a change of threshold. Surplus release would require full funding on a low dependency basis rather than the current buy-out basis. A forward-looking test comes with it: the actuary must certify the scheme is expected to stay above that threshold for three years after payment. Around four in five DB schemes are now in surplus, with the aggregate estimated at £160bn.
HMRC’s side would allow one-off payments direct to members without penal tax charges, treated as pension income and excluded from pension input amounts for annual allowance purposes. Payment can only be made once a member reaches normal minimum pension age, with awards to younger members deferred. The legislation is expected in the 2026-27 Finance Bill, with both packages taking effect on 6 April 2027. The DWP consultation is on GOV.UK. We covered the surplus framework in our report on the rules trustees will have to meet.
The Regulatory Roadmap dates the next two years of pensions consultations in one place, which is the calendar trustees and their advisers have been asking for. The immediate work is narrower: three responses due inside a week, and a surplus regime that changes the funding threshold rather than merely the paperwork. Schemes contemplating release in 2027 need the actuarial three-year test modelled now, not after the regulations are made.
What does TPR expect on AI governance?
TPR has published an AI plan setting out expectations for how AI is governed and used across the pensions sector. Delivery against it sits in the Corporate Plan, under making TPR a more data-driven regulator. Trustees and administrators are expected to establish governance and accountability for their own use of AI and for their providers’. They should understand how AI models use and process member data, and take advice where needed. Fuller guidance is to follow.
The transferable point for law firms is the second limb. Accountability extends to a supplier’s models, not just the ones you licensed yourself. Anyone outsourcing administration needs to know what their administrator’s systems are doing with personal data. That is the same question a firm faces about its own suppliers. TPR’s press releases are collected on its media hub.
Pension scams consultation closes with an SSAS safeguard on the table
The DWP consultation on amending the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021 closed on 21 July 2026, having been announced on 9 June. Responses are now with government and no outcome has been published.
The headline proposal is a targeted safeguard against misuse of Small Self-Administered Schemes, where average losses have risen to £38,400 per person. Where there is no clear link between a saver and the SSAS they are transferring into, a new warning flag would be triggered. The transfer could then be stopped. The consultation also looked at removing friction from legitimate transfers, including the amber flag for overseas investments.
A 2023 review had found the 2021 regulations broadly effective but unnecessarily complex. This is the first step in a wider programme run with the Pension Scams Action Group, which TPR leads. Government has said further measures are being developed, including potential primary legislation. The announcement is on GOV.UK.
PwC finds 80% of legal work resists full automation
PwC published research on 3 August 2026 titled The new rules of legal services: five moves to win as AI rewrites value. It reports that around 80% of the legal market retains meaningful barriers to full automation. The categories it names are courtroom advocacy, complex negotiation, regulated judgement calls, and the matters where a client wants a trusted human in the room.
The counterweight in the same research is sharper than the headline. PwC puts about 22% of fees in work relatively easy to automate, naming transactional commercial contracting for enterprises and patent drafting. Sophisticated clients could bring that work in-house with AI support. Firms expect AI to unlock efficiency gains equivalent to roughly 16% of chargeable hours in 2026, up from 11% a year earlier. PwC estimates AI could deliver £6bn of the legal work currently done by lawyers in the UK.
This is a commercial publication from a firm selling advisory services, and it should be read as such rather than as independent data. It does sit alongside the shadow AI findings in our 3 August roundup, and the changing shape of junior work in our report on the entry-level pyramid. The research is reported by Legal Futures.