SPP Event: Conversations about Consolidation – Scaling-up and Contractual Overrides

SPP Event: Conversations about Consolidation – Scaling-up and Contractual Overrides

As the DC pensions market adapts to the new consolidation requirements introduced under the Pension Schemes Act 2026, scale is no longer simply a strategic commercial ambition but is likely to become a regulatory necessity. However, whilst the direction of travel is clear, the practical realities are considerably more complex. This session will examine what “good scale” will look like in reality, and whether consolidation will genuinely deliver better member outcomes, stronger governance and operational resilience, or simply create larger, “too big to fail” schemes that ultimately limit competition. The panel will explore how schemes, providers and advisers are responding to increased pressure to consolidate, the emerging role of contractual override provisions in facilitating change, and the potential operational, governance and member risks that could arise when scale is pursued without sufficient infrastructure or oversight.

The session will bring together perspectives from both TPR and FCA, alongside industry advisers, and the discussion will focus on the real-world implications of consolidation post-Royal Assent, including where the market may still be underestimating the challenges arising from practical matters ranging from administration capability and contractual constraints through to legacy arrangements and data quality.

Panel:

• Chris Moore, Investment Consultant, The Pensions Regulator
• John Yates, Principal, DC Proposition Leader, Gallagher
• Nike Trost, Head of Department, Wholesale Buyside – Market Analysis and Policy, Financial Conduct Authority
• Hannah Tebbutt, DC and Benefits Consultant, Isio (Chair)