New pension rules and consumer protection: from LGPS to EU package and penalties for data sales

The UK government published its response to the consultation^[1] Access and Fairness regarding the Local Government Pension Scheme (LGPS), foreseeing equalization of survivor pension rights and a restructuring of the so-called death grant payment rules. In practice, this means removing the written nomination requirement for cohabitees for the years 2008–2014 and abolishing the age limit of 75 years for death grant entitlements retroactively from 1.04.2014. The document available on GOV. UK indicates that adjustments may lead to backdated compensation payments calculated in years, although no uniform amounts have been specified for individual cases.

Changes in LGPS

In the same response, the government approved a set of measures aimed at reducing the gender pension gap in LGPS and published guidelines from the Government Actuary’s Department (GAD)^[3] on gender pension gap reporting. The new rules foresee automatic recognition of unpaid leave as contributory after exceeding 14 days, the option to voluntarily continue employer contributions during extended leaves, and a reporting obligation for the gender gap for the 2025 valuation and opt‑out rates from the 2026/27 scheme year. This will increase costs for local government employers and may set a precedent for discussions about crediting leave in Poland.

EU Package and Worker Standards

At the European Union level, the European Parliamentary Research Service (EPRS) summarized a Commission package^[4] dated 20.11.2025 titled Boosting supplementary pensions. The project aims to strengthen PEPP products and IORP institutions, promote auto‑enrollment mechanisms with opt‑out rights, and encourage countries to launch national “pension tracking” systems showing citizens’ complete pension rights. The proposals will be voted on by the European Parliament in March 2026; their implementation will require changes to Polish regulations concerning PPE and PPK as well as information standards aligned with the IDD directive.

In practical benefit administration, precedents have also emerged. The Deputy Pensions Ombudsman (DPO) resolved a dispute over delayed transfer between LGPS and NHS, ordering the employer to cover the transfer shortfall and pay 500 GBP in compensation for distress, and in a case of erroneous calculations the NHS BSA administrator was ordered to pay 1,000 GBP in damages. Concurrently, Osborne Clarke described a “Pension Recovery Plan” for the Civil Service Pension Scheme as a response to widespread service delays, raising the issue of employer and administrator liability.

Investments and Consumer Protection

In the private sector, pressure for improved pension conditions is growing: Nat. West Group became according to Pensions Age the hundredth employer accredited^[6] under the Living Pension standard developed by the Living Wage Foundation^[7]. The standard requires a target contribution level of 12% of salary annually with a minimum employer share of 7% or a cash threshold of 3,150 GBP (including at least 1,840 GBP from the employer). Meanwhile, Scottish Borders Council Pension Fund committed 30 million GBP^[8] to the M&G UK Social Investment Fund, reflecting a trend in infrastructure and housing investments by pension funds.

Despite Europe and the UK, signals from other jurisdictions are also significant: in the USA^[5] several states have changed rules on subsidies and healthcare provision^[9] (e.g. Connecticut launched a temporary Premium Assistance program, Maryland liberalized refill rules and removed pre‑authorization for diabetic drugs, New York set a mileage reimbursement rate^[23] at 0.725 USD/mile retroactive to 1.01.2026, and Tennessee lowered workers’ comp rates by 1.1% and 2%). In California, a settlement concerning violations of the California Consumer Privacy Act involves a penalty of 2.75 million USD and implementation of effective opt‑out mechanisms, increasing pressure to properly stop client data sales. Meanwhile, Bangko Sentral ng Pilipinas (BSP) reminded about Circular No.1048^[12] requiring full transparency and effective complaint procedures.

For the Polish consumer, three conclusions are key^[2]: (1) rising expectations for equal family rights and potential backdated compensations, (2) employer‑sponsored pension standards may tighten under the influence of Living Pension and EU auto‑enrollment requirements, and (3) data protection and effective opt‑outs are becoming real mechanisms limiting the use of client information by banks and insurers. In the coming weeks, it is worthwhile to follow the March work of the European Parliament on the pension package and national responses from regulators: the Financial Supervision Authority, the Ministry of Finance, and the Social Insurance Institution.

Sources

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