Pension Schemes Bill progress and update to Virgin Media clauses

A Pension Schemes Bill 2025 amendment paper was published on December 1, 2025, setting out extensive Government amendments and new clauses ahead of the Bill's report stage and third reading that took place on December 3, 2025. The Bill then moved to the House of Lords for consideration. The second reading in the House of Lords is scheduled for December 18, 2025.

The principal new provisions are:

Virgin Media remedy: drafting changes to the part of the Bill relating to the Virgin Media remedy are proposed. These include clarifying the scope of the exclusion from the remedy's scope where the validity of a purported alteration is or has been in issue in "legal proceedings". Broadly speaking, legal proceedings will be "qualifying legal proceedings" where they are brought before a UK court (rather than the Ombudsman or a Tribunal) and will determine a dispute about a scheme's governing rules, where the parties include the scheme trustees or managers and one or more representative beneficiaries.

“Positive action” triggering exclusion from the Bill’s remedial provisions will not now include steps taken by the scheme’s trustees or managers to alter benefit payments after deciding that an amendment is void for non-compliance with the contracting-out regulations, unless they have been notified to the scheme members in writing.

In a timing change, these provisions will now be brought into force on Royal Assent, instead of two months after Royal Assent as originally proposed.

PPF and FAS compensation: new provisions providing for the PPF and FAS to reflect an individual's pre-1997 pensionable service in certain cases when calculating annual indexation of their compensation. This change was announced as part of the Autumn 2025 Budget.

PPF administration levy: abolish the PPF administration levy and provide for the PPF to meet its own administrative expenses in future. This clause will come into force on April 1, 2026.

In addition, during a Parliamentary debate on December 3, 2025, Pensions Minister Torsten Bell said the Government would “develop statutory guidance for the trust-based private pensions sector” on a wider interpretation of fiduciary duty. This addresses a clause, introduced by Labour MP Liam Byrne, which would allow trustees to include a range of factors when making investment decisions. These include “system-level considerations”, members' views, and the “reasonably foreseeable impacts” of assets or organisations in which the pension scheme invests, including on members' and beneficiaries' standards of living. Mr Bell said the measures would not be “hardwired” into primary legislation, indicating that the Government would consult on the proposals.