Consultations & Formal Responses


The SPP welcomes the proposed introduction of Authorised Member Surplus Payments (AMSPs) but is concerned that restricting payments to members who have reached normal minimum pension age (NMPA) could significantly limit the usefulness of the new provision and create unnecessary administrative and communications challenges.

The SPP welcomes the government’s ambition to harness scale for Defined Contribution (DC) pension schemes but our response to the DWP discussion paper on key elements of the Scale Policy, warns that an extended regulatory timeline risks creating paralysis in industry planning, stifling innovation, and compressing execution risk as the 2030 deadline approaches.

There are also various areas that require urgent regulatory clarity and greater flexibility, particularly regarding the definition of Common Investment Strategies (CIS) and the measurement of scheme scale.

The SPP welcomes the DWP draft Regulations on surplus flexibilities for DB pension schemes as they provide an appropriate framework for well-funded schemes to release surplus while protecting members. However, we are calling for changes to make the regime more practical, particularly for schemes intending to remain on a long-term run-on basis. The proposed process is geared towards one-off payments and could make regular or phased distributions unnecessarily burdensome.

While supporting the fundamental objective of putting the General Levy on a sustainable footing and ensuring regulatory bodies are properly resourced, our consultation response urges the Government to provide a clear, evidence-based justification for these “disproportionate” rises.

Structural deficiencies, soaring housing costs, and shifting work patterns mean millions of UK workers are heading towards an inadequate retirement unless the government enacts significant reforms.

To help solve the crisis, in this response, the SPP have outlined a series of bold interventions that policymakers should consider in order to dramatically boost pension saving and pull forgotten workers into the savings net.

This response sets out SPP's views on the operation of TUPE in relation to pension rights.

The SPP believes the current framework generally provides strong protection for employees while identifying a small number of areas where legislative clarification and simplification could improve outcomes for both employers and employees.

This response to HMRC's technical consultation on the implementation of inheritance tax on pensions from April 2027, highlights a range of operational, legal and practical concerns that we believe must be addressed before the new regime is introduced.