3 March 2026
ZEDRA, award-winning provider of pension and incentive services, has today submitted its response to the FCA’s consultation on the proposed Value for Money (VFM) framework*, welcoming the direction of travel while highlighting areas where further refinement is needed to ensure assessments are robust, proportionate and consistent.
The VFM framework is intended to support a shift in how the workplace pensions industry operates and competes, strengthening transparency and comparability across arrangements.
Commenting on the consultation, Anne Sander, Client Director and Head of the ZEDRA Governance Advisory Arrangement, said: “We see the proposed framework as a positive evolution in how value for money is assessed in workplace pensions. Greater objectivity and consistency in the metrics used to evaluate value should support improved member outcomes over time. However, aspects of the current proposals risk leading to distorted assessments, and we have suggested a number of targeted improvements. In particular, we believe the framework should require five-year forward-looking investment performance metrics, alongside one-year measures for cohorts within five years of retirement and at retirement. This would provide a more meaningful assessment of the value members can reasonably expect to receive. It is also important that GAAs and IGCs have sufficient transparency over the capital market assumptions underpinning forward-looking metrics. This would enable effective challenge of those assumptions, better assessment of backward-looking outcomes, and provide an additional safeguard against potential gaming.
Sander added: “There are also technical refinements that would improve consistency, including clarifying definitions within key transaction metrics, such as ‘payments out to beneficiaries’, and setting out a clear definition of what constitutes a ‘formal request’ for transactions. On complaints metrics, consideration should be given to how cases escalated to the Pensions or Financial Ombudsman are treated, given the time lag between initial complaint and resolution. Expressing this as the number of ongoing cases within a year may provide a more accurate reflection of service experience.
“Finally, while service level performance and complaints data are important indicators, they do not capture the full range of services covered by a scheme’s service charge. GAAs and IGCs should be permitted to apply qualitative judgement where appropriate, particularly where additional services are being delivered, to avoid distorted value assessments. Ultimately, we fully support the FCA’s ambition to strengthen competition and transparency in the workplace pensions market. With targeted refinements, the framework can certainly deliver clearer and more meaningful assessments of value for members but getting these details and refinements right will be critical to ensuring the framework drives genuine improvements in member outcomes.”
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