23 January 2026
The Financial Reporting Council (FRC) has today issued guidance to help UK pension scheme actuaries provide retrospective confirmation to validate historic changes to pension scheme rules.
The new guidance is published ahead of upcoming legislation related to the Pensions Schemes Bill to address uncertainty raised within the UK pensions industry by the “Virgin Media v NTL Pension Trustees” judgment. The judgment highlighted that some pension schemes may be unable to demonstrate that past amendments to their rules were valid, potentially leaving them with higher liabilities than expected.
The Technical Actuarial Guidance published today provides practical, non-prescriptive guidance for actuaries, including examples illustrating how to apply a proportionate approach in collecting information and forming judgements when historic records are incomplete. It sets out a practical framework to support actuaries in the application of their judgment and strengthen confidence that historic changes made to UK pension schemes have complied with legal requirements.
The guidance has been promptly developed in close collaboration with industry, including extensive input from the IFoA and the Association of Consulting Actuaries.
Go to the FRC website to see the release