06 March 2026
Sacker & Partners LLP (Sackers), the UK’s leading specialist law firm for pensions and retirement savings, today have responded with their comments to the joint consultation by the FCA, the DWP and TPR on the new Value for Money (“VFM”) framework for DC pension schemes (the “Framework”) (see our Alert for details).
Andy Lewis, Partner, comments: “We welcome the policy goal of ensuring a strong focus on value for money rather than cost, regardless of pension arrangement type, and we appreciate the collaborative work between the DWP, the FCA and TPR to develop consistent cross-industry VFM proposals following feedback to the 2024 consultation. Our response highlights several remaining practical concerns about scope, timing, data comparability and the risk of unintended consequences for schemes and providers which we hope will be addressed in the final Framework. To reduce complexity, we would support focussing VFM on a more limited range of “true” default arrangements, at least initially while the Framework beds in. Many trust-based schemes have “inadvertent” default arrangements created through historic fund changes. Including these increases the burden to industry and also risks missing the policy target of protecting members at greatest risk of receiving poor value.
“The Framework should encourage arrangements which are genuinely in a position to improve value to do so quickly. We suggest allowing amber arrangements a grace period to improve before they are required to close to new business. We also suggest reconsidering the timing of data publication, assessments and improvement plans. We urge the authorities to provide DC schemes with reassurance that unhelpful duplication between the chair’s statement requirements and the VFM framework will be removed. Unless changes are introduced quickly, schemes may face overlapping and inconsistent disclosure requirements for different types of default across different reporting cycles.
“Producing a VFM assessment will require a significant amount of resource. Schemes will feel this acutely when the Framework is first implemented but also on an ongoing basis as assessments become part of the annual cycle. A careful balance is needed to ensure that this is achievable in practice and that the assessment will be genuinely useful for schemes, employers, the industry and pension savers. But for the first assessments to be ready in 2028 based on 2027 data, it’s vital that schemes and providers are given clarity on the final Framework soon.”
Read our full consultation response.
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