HL UK Pensions Law Digest 19 March 2026

Welcome to our latest update, in which we cover: 

The Pensions Regulator: a new scam alert in relation to impersonation fraud

• The Pensions Regulator (TPR) has published a scam alert, urging immediate action in response to an increase in impersonation fraud;

National Insurance Contributions (Employer Pensions Contributions) Bill: House of Lords amendments

• The House of Lords has made certain amendments to the National Insurance Contributions (Employer Pensions Contributions) Bill at the Report Stage.

The Pensions Regulator issues a scam alert urging trustees and administrators to take steps to protect scheme members from impersonation fraud

On 11 March, the Pensions Regulator (TPR) published a scam alert urging pension scheme trustees and administrators to be vigilant, following a rise in impersonation fraud. It follows a similar alert in September 2025, which indicated that account-hacking and impersonation techniques were being used to gain unauthorised access to pension scheme members' accounts.

The alert, issued in conjunction with the City of London Police, highlights a heightened risk to Africa based members of UK pension schemes, based on a Report Fraud analysis which identified a sharp rise in this type of fraud in 2025. This follows a year-on-year increase since 2016.

Impersonation fraud methods

The alert outlines various impersonation fraud methods:

• Identity theft and account takeover. Fraudsters gain access to members' personal information by hacking their email accounts, intercepting post or through direct contact.
• Fraudulent duplicate accounts. Fraudsters set up fake accounts in the member's name.
• Weak credential exploitation. Poorly secured account credentials, such as weak passwords or one-step verification, allow accounts to be accessed.
• Fraudulent death claims. With access to the member's account, fraudsters divert pension funds belonging to deceased members to an alternative bank account without the next of kin's knowledge.

Recommended actions

The alert sets out five recommended actions to help protect members. Trustees and administrators should:

• Report any suspected fraud immediately to Report Fraud (which has replaced Action Fraud as the national platform for reporting cybercrime and fraud). The alert links to Report Fraud's online reporting tool.
• Review the scheme's identity and verification checks, including systems and controls. The alert advises schemes to ensure that staff are trained to identify fraudulent documentation, especially for death and ill-health claims. The alert also links to Pension and Administration Standards Association (PASA) guidance (May 2025) on protecting identities during high-risk events.
• Review data security for letters and documents that are posted to overseas addresses. The alert suggests using recorded delivery and that schemes avoid sending personal/sensitive information in envelopes that show their organisation's name.
• Encourage members to strengthen online security by adopting two-step verification and using stronger passwords. The alert also advises schemes to raise awareness of the heightened risk of pensions fraud for members of UK pension schemes who live in Africa.
• Signpost members to resources such as Stop! Think Fraud, the Pension Scams Action Group (PSAG)’s "steps to stay scam safe" leaflet and the City of London Police Identity Fraud Guidance.

Return to Contents.

House of Lords amends National Insurance Contributions (Employer Pensions Contributions) Bill

The House of Lords has made several amendments to the National Insurance Contributions (Employer Pensions Contributions) Bill (the Bill) at the Report Stage. These were not government sponsored changes.

In broad terms, the Bill implements government proposals to introduce an annual cap on the amount of pension contributions which qualifies for full national insurance relief, with effect from the tax year 2029-30

The key amendments agreed at the Lords Report Stage, if enacted, would:

• Increase the annual cap from £2,000 to £5,000;
• Exempt basic rate taxpayers from the cap; and
• Exempt certain small or medium sized enterprises and charities from the cap.

However, the government is expected to seek to reverse the amendments when the Bill returns to the House of Commons.

Return to Contents.

Please click here to subscribe to our mailing list if you do not currently receive our digests directly to your mailbox.

Authored by Susanne Wilkins.