The Pensions Act 2004 (Code of Practice) (Revocation) Order 2026 is a narrow statutory instrument, but it makes a clear change to the regulatory framework for collective pensions. According to the text laid before Parliament on 2 July 2026, the Order revokes The Pensions Regulator’s code of practice on the authorisation and supervision of collective defined contribution schemes with effect from 31 July 2026. The instrument was made by the Secretary of State under section 92(1) of the Pensions Act 2004, with the consent of The Pensions Regulator as required by section 92(2). It applies in England and Wales and Scotland, and was signed for the Department for Work and Pensions by Parliamentary Under-Secretary Torsten Bell.
The practical point is that the Order removes a code of practice, not the statutory regime itself. The Explanatory Note says the code being withdrawn is the code brought into effect on 1 August 2022, which has until now set out the regulator’s published expectations for authorisation and ongoing supervision of these schemes. That distinction matters. A code of practice helps trustees, employers and advisers understand how The Pensions Regulator reads the legislation and what evidence it is likely to expect. Revoking the code does not switch off the underlying legal duties in pensions legislation; it removes guidance that is no longer fully aligned with the current scheme perimeter.
The reason for the change is set out directly in the Explanatory Note to the Order. A new code of practice will be issued to reflect amendments made by the Occupational Pension Schemes (Collective Money Purchase Schemes) (Extension to Unconnected Multiple Employer Schemes and Miscellaneous Provisions) Regulations 2025. Those 2025 Regulations widened regulatory oversight so that collective money purchase arrangements can include unconnected multiple employer schemes. The 2022 code was written before that extension. On that basis, the revocation is best read as a housekeeping measure designed to make way for a replacement code that matches the expanded legal framework.
For readers outside the pensions sector, the terminology can obscure what is changing. Collective defined contribution schemes are generally dealt with in legislation as collective money purchase schemes, a model in which contributions are fixed but retirement outcomes are not guaranteed in the way they would be in a defined benefit scheme. Because the structure depends heavily on scheme design, actuarial assumptions, communications and governance, regulator guidance carries real weight. A revised code is therefore not a minor drafting exercise. It is the document that will help firms judge what The Pensions Regulator expects when schemes seek authorisation or when existing arrangements are supervised.
The main groups affected are likely to be trustees and scheme managers of collective schemes, employers considering participation, administrators, actuaries, legal advisers and firms developing multi-employer pension propositions. For those organisations, the key date in the Order is 31 July 2026, when the current code falls away. In practical terms, that means compliance teams should check internal policies, application material and training notes that still cite the 2022 code. Where processes are built around that document, cross-references may need to be updated once the replacement code is issued. The statutory conditions in the pensions legislation continue to matter throughout, so the immediate task is not policy redesign but document control and regulatory monitoring.
The Explanatory Note also states that no full impact assessment has been produced because no impact, or no significant impact, on the private, voluntary or public sectors is foreseen. That is consistent with the limited legal effect of the instrument itself. The Order does not create a new authorisation test, expand benefits or impose a fresh reporting duty on its own terms. Even so, the absence of a formal impact assessment should not be read as meaning the change is irrelevant. In regulated pensions markets, codes of practice shape how statutory rules are applied in day-to-day supervision. A revised code for unconnected multiple employer arrangements may alter the level of detail expected in governance evidence, systems controls and member communications, even where the primary legislation is already in place.
From a policy perspective, this is a targeted revocation rather than a substantive retreat from CDC regulation. The Department for Work and Pensions has used a short Order to remove a code that is tied to the pre-2025 position, while The Pensions Regulator prepares a replacement better suited to the wider category of schemes now within scope. For the sector, the immediate message is simple. The current code will be revoked on 31 July 2026; the authorisation and supervision regime remains; and the next document to watch is the new code of practice that will translate the 2025 extension into operational expectations.