Documents


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.

This SPP paper highlights a critical structural mismatch in the UK economy - UK retirees currently hold an estimated £3.84 trillion in housing wealth, yet face an aggregate annual retirement income deficit exceeding £48 billion.

Fragmented advice, separate regulatory regimes, and tax barriers like stamp duty prevent people from making holistic decisions about their wealth.

This paper synthesises insights from a major industry roundtable of leading actuaries, trustees, legal advisers, investment managers, and covenant specialists, facilitated by the SPP.

The paper challenges traditional industry momentum by examining how improved funding positions, a £160 billion aggregate surplus across UK DB schemes, and new alternatives such as superfunds and capital run-on strategies have transformed the endgame landscape.