Catalyst: DC pensions

DC PENSIONS TECHNICAL UPDATE   |   WINTER EDITION

Catalyst:
DC pensions

DC PENSIONS TECHNICAL UPDATE   |   WINTER EDITION


Notes from our editors 

This edition of Catalyst captures a rather hectic end to 2024, wherein the DC pension market found itself at the centre of the mainstream UK news cycle on more than one occasion thanks to the back-to-back spotlights of the Government’s Autumn Budget and the Chancellor’s subsequent Mansion House speech. It has been fascinating to hear the different perspectives on the proposed changes to how DC pension schemes operate, and no doubt there will be more touch points throughout 2025 as various consultations come to a close, which we look forward to covering in future editions. But this was by no means the only topic on the minds of our clients – in this edition, we also cover developments on other pressing issues, including ESG, productive investments, and the ever-looming Pensions Dashboards. 

Mark Futcher
Partner and
Head of DC

Sonia Kataora
Partner and
Head of DC Investment

Our updates

Headline updates

Mansion House Speech

As announced by Chancellor Rachel Reeves in her Mansion House Speech on 14 November 2024, the Government has proposed the creation of pension “megafunds” as part of major reforms for the pensions market. A consultation on these reforms – Pensions Investment Review: Unlocking the UK pensions market for growth – has been opened and runs until 16 January 2025.

The Government has emphasised that the future of workplace DC schemes lies in “fewer, bigger, better-run schemes” that can “deliver better returns” and “boost investment in the UK”. To accelerate and facilitate scale and consolidation in the DC market, the following measures are proposed:

  • Minimum Size Requirements and Limits: Minimum size requirements for DC default arrangements in multi-employer schemes used for automatic enrolment and limits on the number of such arrangements;
  • Bulk Transfer of Assets: Allow individual contracts to be overridden to facilitate the bulk transfer of assets from contract-based schemes without individual savers’ consent, subject to appropriate protections.

Single-employer schemes would be excluded from these proposals, as a proposed new Value for Money framework is being designed to ensure these schemes achieve value or move to consolidate. The Government is also:

  • seeking views on whether other schemes with specific characteristics, such as sharia-compliant funds, should be excluded in the public interest;
  • seeking views on the role of employers and advisers, with proposals to encourage a shift in focus from ‘cost’ to ‘value’, following concerns that excessive focus on the former has resulted in less attention on other scheme quality metrics and limited the ability for pension schemes to invest in a broader set of asset classes; and
  • consulting on proposals to set the Local Government Pension Scheme on a clearer, firmer, long-term path to scale and consolidation, along with measures to improve funding, pool governance and drive local investment.

Action: We are responding to the consultation and have taken soundings from clients, in particular on the role of employers and proposed executive sponsorship of pension matters. 
 

Autumn Budget 2024

The Government’s Autumn Budget aims to "fix the foundations of the economy and deliver change by protecting working people, fixing the NHS, and rebuilding Britain." Key policies focus on "strengthening the fiscal framework", "supporting people with the cost of living" and "raising revenue to fund public services".

Key points included:

  • The announcement that unused pension savings will be included in estates for the purposes of Inheritance Tax from April 2027. The Government has launched a consultation on the implementation, with further consultation on draft regulations expected in 2025.
  • Employer NI will increase from 13.8% to 15% in April 2025 and the earnings threshold for employer NI will drop from £9,100 pa to £5,000 pa. These measures will add to employment costs alongside a minimum wage hike. However, higher employer NI will increase saving from pension salary sacrifice.
  • The state pension triple lock will be maintained, with state pension increasing by 4.1% from April 2025. This will raise the weekly amount of the new state pension from £221.20 in 2024/25 to £230.25 in 2025/26.

Our experts dive deeper into these announcements and the impact on employers in this blog post.
 

Quick updates

  • Following a short technical consultation, two sets of regulations have been enacted to address issues identified in pensions tax legislation following the removal of the Lifetime Allowance from 6 April 2024. These regulations took effect from 18 November 2024 and apply retrospectively from 6 April 2024. Action: Trustees should check with their administrators that their systems and processes will be amended to take into account these changes. 
  • The Financial Conduct Authority (FCA) launched a consultation in December 2024 on proposals for targeted support for pension savers to fill the gap between regulated holistic advice and neutral, fact-based guidance services, such as Pension Wise. Action: Trustees should be putting at-retirement solutions firmly on their to-do list, and the availability of guidance and advice services forms a key part of any solution, so trustees will want to understand what their provider may be developing in this area, much of which will be influenced by the outcome of this review.

TRUSTEE UPDATES

Trustee updates

New ESG resource

On 14 October 2024, TPR announced a new central Environmental, Social, and Governance (ESG) resource to assist trustees in moving beyond basic compliance with regulatory requirements. This aims to support trustees in integrating ESG factors more effectively into their investment strategies and decision-making processes.

Key features of the resource include:

  • Practical guidance on implementing ESG considerations
  • Case studies showcasing best practices
  • Tools for assessing and improving ESG integration

TPR emphasises that effective ESG integration can lead to better long-term outcomes for pension savers. Trustees are encouraged to use this resource to enhance their understanding and application of ESG principles, moving beyond mere compliance towards more impactful and sustainable investment practices.

This development underscores the growing importance of ESG in pension scheme governance and aligns with broader regulatory trends promoting responsible investment.

Action: Trustees should review the new resource and use this to help inform and benchmark their approach. 

Productive finance – navigating trends and challenges

Recent publications from the Pensions Policy Institute (PPI) and the Society of Pension Professionals (SPP) provide complementary insights into the evolving landscape of UK pension investments, highlighting both current trends and potential solutions for optimising long-term returns.

The PPI report reveals significant shifts in pension scheme asset allocation, including:

  • a shift towards more diversified portfolios, reflecting broader macroeconomic trends and regulatory influences; and
  • DC schemes, in particular, are increasing allocations to private markets, infrastructure, and sustainable investments to enhance returns and meet members’ evolving expectations.

These trends reflect schemes' efforts to enhance returns and manage risks in a complex economic environment. However, the SPP paper, "Solving the UK investment puzzle", identifies persistent challenges in the UK investment landscape that may hinder these efforts, such as:

  • barriers to efficient capital allocation in UK markets;
  • regulatory constraints limiting investment in productive assets; and
  • sub-optimal collaboration between pension schemes and asset managers.

These insights offer trustees and investment advisers valuable perspectives for navigating the UK investment landscape. By understanding broader market trends and potential regulatory reforms, schemes can work towards optimising their investment strategies to enhance long-term returns and better serve their members.

Quick updates

  • On 11 November 2024, the Financial Reporting Council (FRC) launched a consultation on proposed updates to the UK Stewardship Code. This initiative aims to strengthen the Code's effectiveness in promoting responsible investment practices and enhancing the quality of stewardship activities. Action: Trustees and investment advisers are encouraged to review the consultation document and consider its implications for their stewardship activities. If you are considering responding to the consultation (which closes on 19 February 2025), we would be happy to assist you.
  • On 27 November 2024, TPR announced significant changes to its regulatory approach in response to the Mansion House reforms and the expected increasing size and systemic importance of pension schemes. Action: Trustees and advisers should be prepared for increased regulatory scrutiny and engagement, particularly for larger schemes. This emphasises the importance of robust governance frameworks and risk management practices in navigating the evolving regulatory environment.
  • TPR released its Compliance and Enforcement Bulletin covering the period from January to June 2024. Amongst other things, this bulletin noted that TPR exercised its powers ten times in relation to detailed Value for Members (VFM) assessments, applicable to trust-based schemes with under £100m in total assets. Action: Trustees in scope of the detailed VFM requirements must complete annual assessments and if it is concluded that value is not provided, must take action to either improve or wind up the scheme and transfer the rights of their members elsewhere. These assessments and decision-making around any subsequent actions must be robust and documented given TPR’s interest and the general policy direction towards greater consolidation of DC schemes. Barnett Waddingham can help trustees navigate their way through these issues.

WIDER UPDATES

 

Wider updates

Pensions Dashboards updates

In a statement on 22 October, Pensions Minister Emma Reynolds confirmed the Government's commitment to the current connection timetable. Staging dates will begin in April 2025, with an overall statutory connection deadline of 31 October 2026. A launch date for public use has yet to be confirmed, however the Government is taking steps to help the public understand the benefits of using a pensions dashboard. The Government plans to prioritise the launch of the government-backed MoneyHelper dashboard before enabling the connection of commercial dashboards.

A survey conducted by the Pensions and Lifetime Savings Association (PLSA) before the statement revealed that 90% of schemes are confident they will meet their connection deadlines for regulatory compliance, albeit nearly half of schemes have concerns over the impact their data quality will have on their dashboard readiness.

Elsewhere, the Pensions Administration Standards Association (PASA) has published a Dashboards Toolkit to support connection of additional voluntary contributions (AVCs) to the pensions dashboard ecosystem. This includes a checklist of activities that trustees with AVCs should consider when arranging to connect, either when all scheme benefits (including AVCs) are being connected by a single party, or if the AVC provider can connect on behalf of trustees. A list of connection approaches offered by the major AVC providers is being maintained.

Action: Trustees should check their connection date as outlined in the amended connection timetable and should be working with their administrators and providers to establish how connection (including AVCs) will be completed and what further work is required to facilitate this.

Previous editions

Catalyst - Autumn 2024

Exploring significant shifts in the UK pensions landscape following the election of a new Government, which set the tone for transformative changes.

Find out more

Catalyst - Summer 2024

Diving into a time of transition for the pensions industry in the UK, with not only the appointment of a new Secretary of State for Work and Pensions in Liz Kendall, but a new Government as well. 

Find out more

Catalyst - Spring 2024

Detailing new reports and guidance on fiduciary duties relating to sustainability considerations, private market investments, cyber security and Pensions Dashboards.

Find out more

The Pensions Regulator
(TPR) updates