Westminster Policy News & Legislative Analysis

LGPS Governance Regulations 2026 Set New Duties in England and Wales

The Local Government Pension Scheme (Amendment) (Governance) Regulations 2026 were made on 19 May 2026, laid before Parliament on 21 May 2026 and come into force on 30 June 2026. As published on legislation.gov.uk as S.I. 2026/545, the instrument amends the Local Government Pension Scheme Regulations 2013 for England and Wales and draws on powers in the Public Service Pensions Act 2013 and the Pension Schemes Act 2026. The policy effect is clear. The regulations move the LGPS away from a relatively narrow governance compliance statement model and into a broader framework built around named accountability, mandatory governance documents, knowledge standards and formal review. For administering authorities, this is not a minor drafting exercise. It resets how LGPS governance must be organised, recorded and published.

The first new duty is the creation of the LGPS senior officer role. Under new regulation 53A, every administering authority must appoint an officer with senior responsibility across all pension functions within six months of 30 June 2026, which sets the first deadline at 30 December 2026. That officer must ensure that the fund is properly managed and resourced across administration, investment and governance, in line with guidance issued by the Secretary of State from time to time. The role is also ring-fenced. In a local authority, the LGPS senior officer cannot at the same time be the section 151 officer, the head of paid service or the monitoring officer. For a single purpose pension authority, the position is different: if the head of paid service is an employee of that authority, that person must hold the LGPS senior officer post. The regulation also states expressly that none of this alters the statutory responsibilities of the authority's finance officer.

A second structural change applies wherever scheme functions are delegated. If an administering authority delegates functions under the LGPS Regulations or section 101(1)(a) of the Local Government Act 1972 to a committee, sub-committee or officer, it must appoint an independent person to support the discharge of those functions. The appointment must be made within six months of the duty arising, and the independent person must be independent of both the Secretary of State and the authority. The legislation.gov.uk text states that this support must extend to investment strategy, governance and administration. For single purpose pension authorities, the independent person may be appointed to a committee or sub-committee as a voting or non-voting member. For other administering authorities, the main point is external challenge: delegated decision-making can continue, but it now has to sit alongside a formally independent role.

The regulations also remove the existing governance compliance statement in regulation 55 and replace it with three standing documents under new regulation 55A: a governance strategy, a training strategy and a conflicts of interest policy. This is a marked change in both format and substance. The governance strategy must now set out whether functions are delegated, how delegation works in practice, how often committees meet, how substitutes are handled, whether scheme employers or members are represented, whether those representatives can vote, how absent voices will be reflected if they are not formally represented, how the authority will secure appointment of an independent person, how the structure fits Secretary of State guidance, and how the local pension board sits within the wider framework. Authorities may publish the documents separately or as a single combined publication, but they must review them at least once in each valuation period and after any significant change.

The conflicts policy is especially significant because the regulations define the issue broadly. It must cover individual conflicts involving committee members, the section 151 officer, the LGPS senior officer and any independent person. It must also address conflicts between the authority's role as administering authority and its other roles, as well as conflicts linked to asset pool companies, strategic authorities, local pension board members and other office-holders or employees with relevant influence. Before preparing or updating the new documents, the authority must consult such persons as it considers appropriate, and any revised version must be published. In practical terms, the rules push funds towards fuller record-keeping and clearer decision trails, particularly where pension fund interests intersect with wider local authority, pooling or regional governance arrangements.

New regulation 55B adds a formal knowledge and understanding requirement for people exercising delegated functions and for the LGPS senior officer. Within a reasonable period after appointment, those individuals must be conversant with the scheme rules and with adopted policy documents on administration, and they must hold knowledge and understanding of pensions law appropriate to their functions. The explanatory note on legislation.gov.uk says the model is similar to the standard already applied to local pension board members under section 248A of the Pensions Act 2004. The same instrument tightens related documentation duties. The pension administration strategy moves from optional to mandatory, must be reviewed at least once in each valuation period and after material policy change, and must be prepared, revised and published in line with Secretary of State guidance. Pension fund annual reports may now include the text of the new governance documents or a link to them, rather than reproducing the full text in every case.

The strongest oversight change may be new regulation 116A. It requires administering authorities to arrange governance reviews by a suitable person who is independent of both the Secretary of State and the authority and who, in the authority's reasonable opinion, has sufficient LGPS knowledge to conduct the review properly. The Secretary of State may also direct an ad hoc governance review at the authority's expense. If no ad hoc review is required first, the first periodic governance review must be completed by 31 March 2028. After that, further periodic reviews must be completed by the end of the valuation period following the valuation period in which the most recent governance review was completed. The reviewer must prepare a report and send it to both the Secretary of State and the administering authority, and the authority must publish that report as soon as practicable and no later than the date by which the review had to be completed. The regulations also treat the review cost as an administration expense of the pension fund.

Taken together, the changes are more than procedural. According to the explanatory note on legislation.gov.uk, the instrument is intended to strengthen and update governance arrangements for administering authorities. The old regime centred on a governance compliance statement. The new regime centres on a named senior officer, an independent person where functions are delegated, published governance, training and conflicts documents, mandatory administration strategy work, and recurring external review. The note also states that no impact assessment was produced because no, or no significant, effect on the private or voluntary sectors was foreseen. That does not reduce the scale of change inside the LGPS itself. For pension committees, officers, employers and scheme members, the regulations create clearer lines of responsibility, more documents that must be kept current and public, and a firmer basis for testing whether a fund's governance meets the statutory standard. A large share of operational detail will still sit in guidance issued by the Secretary of State from time to time, but the legal baseline is now much more defined.