DP26/2: Guided Retirement

This is not yet binding, but the direction of travel is clear: policymakers want default retirement journeys that help members make informed choices without crossing into regulated advice. For compliance teams, the central challenge is the advice/guidance boundary — firms will need to scrutinise how far personalised support can go before it becomes a regulated recommendation, and how that sits alongside Consumer Duty outcomes on informed decision-making. Providers of contract-based schemes should begin mapping their current at-retirement customer journeys, communications and default pathways against the anticipated expectation of a guided — rather than purely information-based — retirement experience.

Trustees and scheme governance bodies across trust-based arrangements should similarly assess member support provision, value for money and data readiness. Actionable next steps: coordinate a cross-functional review (product, conduct, legal, pensions technical, operations) ahead of the 22 December 2026 response deadline; decide whether to respond individually or via trade bodies; assess delivery capability for digital guidance and triage tooling; and monitor for a subsequent policy statement or rules. The deadline is tight, so early engagement is advisable.

This is moderate-to-significant for pensions firms, but informational for those without retirement provision.