M

Member

Speaking in the House of Lords on 23 February 2026

Debate

Pension Schemes Bill

Contribution

Amendment 210, tabled in my name, seeks to review pension communications and financial promotion rules. The case for a review rests on a practical difficulty that has become increasingly evident within the pension sector. The current definition of direct marketing is extremely broad. Under the Information Commissioner’s interpretation, any communication intended to prompt a response is likely to fall within scope. In the context of pensions, that can include communications, which providers are required to send in order to comply with statutory or regulatory duties. Once a communication is categorised as direct marketing, it becomes subject to the Privacy and Electronic Communications Regulations. The compliance risks are significant. Pension providers may face substantial penalties if they misjudge the classification of a message, even where the purpose of that message is to meet a legal obligation or to protect members from foreseeable detriment.

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