Consultations & Formal Responses


This response sets out the SPP’S views on government proposals to extend access to the LGPS to Mayors and Councillors; to prevent contribution rate shopping by Academies; and to New Fair Deal proposals to help ensure continued access to the LGPS for outsourced workers.

This response acknowledges that there are arguments for and against Retirement CDC schemes being made available in the retail environment; strongly supports the introduction of a ‘cohorting’ approach; and agrees that there is a strong case for a charge cap to be introduced.

If the Government introduces their Guided Retirement requirements on DC schemes in advance of Retirement CDC being made available, schemes may not have much appetite to revisit their Guided Retirement options in the short term. This could represent a substantial missed opportunity.

SPP's short response to The Pensions Regulator's Enforcement Strategy consultation, which expresses support for the broad thrust of the proposed changes whilst detailing some areas where unintended outcomes could arise and where further clarification would be helpful.

This SPP response to the government’s latest review of the SPA, highlights that if wider terms of reference, including the purpose of the State Pension, had been provided, this would have enabled more relevant factors to be considered and potentially better outcomes.

The response addresses questions relating to an increase in the SPA and proposals for an automatic adjustment mechanism too.

The Society of Pension Professionals (SPP) response to the
House of Lords Economic Affairs Finance Bill Sub-Committee
October 2025 call for evidence on reforming inheritance tax: unused pension funds and death benefits.

The SPP has two key concerns with this draft legislation – the proposed definition of “tax adviser” and therefore the scope of the legislation and the current omission of any exemption for pension professionals.

The SPP supports the concept of targeted support for pensions and believes it could play a part in improving savings decisions and preferences, reducing fees and charges, and increasing consumer confidence.

However, our response seeks to highlight potential barriers to success and areas of concern, making various suggestions for improvement.

The SPP very much supports the Bill and most of its broad aims from PPF levy flexibility and surplus release to the concept of default decumulation and improving Value for Money for DC schemes. However, we have made various suggestions as to how the Bill could be improved and we fundamentally oppose the the reserve power for government to mandate investment in private market assets.

The SPP agrees with the government that these proposals will fundamentally improve fairness in and access to the Local Government Pension Scheme (LGPS).

However, the SPP response also highlights the potential for “disruptive administrative impacts” given the numerous other projects being dealt with by the LGPS from dashboards to the McCloud remedy.

There is widespread adoption of AI within the UK pensions industry, with 87% of respondents to a recent SPP survey confirming that AI is being used by their firm. However, the survey also revealed that more than three quarters of respondents (77%) currently used AI in only 1%-5% of their services, suggesting that there is great potential for future use. This response provides further detail about such usage.

The SPP believe that the FRC have done a good job in dealing with what is an increasingly complex area. However, there are some improvements that could be made, both for clarity and to reduce the amount of work needed that wouldn’t add material value to the advice. If these changes are made, the new Technical Actuarial Standard for pensions is likely to provide strong support for practitioners carrying out actuarial work under the new DB funding regime.