Consultation outcome

Amendments to the Firefighters’ Pension Scheme (England): retained firefighters – Government response

Updated 4 December 2025

1. Summary and introduction  

1.1 Retained firefighters are part-time firefighters who only attend a fire station after having received an emergency callout, unless undertaking training or scheduled duties. Retained firefighters may also have other occupations, but, when called upon, they will perform firefighting duties.  

1.2 Historically, retained firefighters did not have any entitlement to membership of the Firefighters’ Pension Scheme 1992 (the ‘1992 Scheme’). A group of retained firefighters brought legal proceedings against the government in the case of “Matthews v. Kent and Medway Towns Fire Authority (2006)” (‘the Matthews case’) under the Part-time Workers (Prevention of Less Favourable Treatment) Regulations 2000 (‘the PTWR’). The claims related to their exclusion from the 1992 Scheme, which then provided benefits solely to full-time regular firefighters. 

1.3 Following the final determination in the case, a new pension arrangement was introduced through the creation of modified provisions in the 2006 Scheme (the ‘modified scheme’) on 1 April 2014.   

1.4 The modified scheme currently provides preferential pension terms, similar to those provided by the 1992 Scheme, to retained firefighters who were employed between 7 April 2000 and 5 April 2006 inclusive, with the option to purchase pre-7 April 2000 service where the individual has continuous retained service (the ‘Matthews remedy’). 

1.5 Fire and Rescue Authorities (FRAs) are currently implementing the 2023 options exercise, which is the process that allows eligible retained and former retained firefighters to elect to join the modified scheme and become special members.

1.6 In 2024, the Home Office (which was the department responsible for firefighters’ pensions policy until 1 April 2025) was advised by the Local Government Association (LGA) and fire sector stakeholders that a significant number of FRAs would not be able to complete implementation of the 2023 options exercise by the deadline of 31 March 2025. Additionally, the Home Office was made aware of a number of areas that should have been covered by the Matthews remedy but had not been captured by the legislative changes introduced in 2014 and 2023. 

1.7 On 23 December 2024, the government launched a consultation on the government’s commitment to provide additional remedy and flexibility to those members who were employed as retained firefighters between 7 April 2000 and 5 April 2006 inclusive by providing access to the modified scheme.  

1.8 The consultation sought views from interested parties on proposals to amend the Firefighters’ Pension Scheme (England) Order 2006 (the ‘2006 Scheme’) to allow the following: 

• The payment of a missed pension lump sum payment/survivor’s missed pension lump sum payment in respect of a deceased individual who would have been entitled to a pension (or a higher pension) under the Matthews remedy. This proposal would provide payment of any lost member pension (pre-commutation) and survivor pensions to the deceased individual’s survivor or estate. 

• The extension of the eligibility criteria for an additional death grant payment, payable in respect of those individuals who did not join (or did not get an opportunity to join) the modified scheme during the 2014 options exercise.   

• A minor clarification to the formula for calculating the extended death grant to change the reference from ‘additional death grant’ to ‘extended death grant’ to remove any misunderstanding. 

• The extension of the option to convert relevant standard service in the 2006 Scheme to special service in the modified scheme to include members who joined the modified scheme as special deferred members.  

• The option for members who join the modified scheme as special pensioner members, and who are in receipt of a ‘member initiated early payment of pension’, to convert their standard service to special service. This cohort was missed from the early legislative changes.  

• The option for members who joined the standard 2006 Scheme, and who subsequently opted out of the standard 2006 Scheme prior to 1 April 2015, to purchase period/s of opted out service as special service under the modified scheme.

• The payment of new awards under these changes to be paid after the options exercise closing date in circumstances where the individual has not received a notification from their employer.

• The extension of the period for FRAs to implement the Matthews remedy in circumstances where they were unable to meet the original 31 March 2025 deadline. 

1.9 The consultation was open for an 8-week period and closed on 17 February 2025. During the consultation period, the Home Office engaged with a variety of stakeholders, to include the Local Government Association and the Firefighters’ Pensions Scheme Advisory Board. During these engagements, the opportunity was taken to clarify the technical aspects of the proposals. 

1.10 A total of 49 responses were received. These included submissions from FRAs, employer representatives, pension administrators, payroll providers, member representative bodies, and individual scheme members. Responses were submitted via email and through structured response templates and all were fully considered throughout the analysis.  

1.11 The proposals received a positive response during consultation. However, a notable proportion of respondents felt that certain elements did not go far enough to address key concerns. More detail is provided in section 3. 

2. Final policy position and implementation 

Final policy position 

2.1 After carefully considering the responses, the government has decided that it will proceed with implementing the proposals consulted on as set out above, with the following changes:  

i. Missed pension lump sum payment (Question 1) – The calculation of the proposed lump sum payment has been modified and now assumes that the deceased individual would have commuted the maximum of their annual pension for a retirement lump sum. This better reflects the scheme experience and, in most cases, will result in a higher lump sum payment. Flexibilities have also been introduced to allow FRAs to determine the deceased’s pay and service where no, or limited, information is available; 

ii. Survivors missed pension lump sum payment (Question 2) – The beneficiaries of the proposed survivors missed lump sum payment has been changed to restrict payment to living survivor beneficiaries only, in line with the policy intention.   

iii. Additional death grant (Question 3) – the formula for calculating the grant has been modified to provide for the calculation of the grant for deceased individuals who had not previously joined the modified scheme.    

iv. Extended deadline for new benefits/2023 options exercise (Question 8) - the consultation originally proposed a 12-month extension to 31 March 2026. Due to ongoing delays in finalising the amending legislation, the proposal has been modified to extend the deadline by 12 months from when the associated amending legislation comes into force. 

vi. Miscellaneous technical changes – additional changes to the original proposals have been made to introduce flexibilities to provide FRAs sufficient time to identify and notify eligible individuals of their pension entitlements under the modified scheme, and to extend the scope of the provisions to cover newly identified cohorts of eligible individuals.   

2.2 It is also worth noting that a number of drafting errors in the draft order, and erroneous references in the explanatory note were identified during the consultation. These have been reviewed and corrected where necessary. 

2.3 The proposals to introduce new awards in respect of deceased individuals originally gave FRAs a two-month period to notify beneficiaries of their entitlement. The general view amongst respondents was that this would not be sufficient to implement the changes. On this basis, the government has agreed to allow additional flexibility in that FRAs will be required to notify eligible individuals as soon as possible, and no later than 12 months after the legislation comes into force, where the initial two-month deadline cannot be met.  

2.4 A number of matters were raised during the consultation which sit outside the scope of the consultation, such as clarification on the tax treatment of the new lump sum payments. These have not been addressed in the government response.   

2.5 Respondents emphasised the need for the Government’s Actuary’s Department (GAD) to provide an updated calculator promptly to enable FRAs to process the new benefits introduced under this consultation. In response, GAD have been commissioned to further develop the Matthews calculator to cover missed member pension lump sum calculations, calculations for the purchase of periods of opted out standard service as special service, and calculations to extend the option to convert to include special deferred members. For more complex cases where the calculator cannot be developed, this will be included in the manual cases process. The calculator user guide will include a supporting example for each of these calculations. 

Implementation 

2.6 The government is grateful to all those who took the time to respond to this consultation. The views, evidence, and insights provided have been carefully considered and have played a vital role in shaping the final policy position. 

2.7 The government remains committed to ensuring that the Firefighters’ Pension Scheme is fair, sustainable, and continues to meet the needs of its members. The proposals outlined in this consultation reflect our ongoing efforts to address historic inequalities, improve scheme accessibility, and provide clarity and consistency in the application of pension entitlements. 

2.8 Responsibility for firefighters’ pensions policy has transferred from the Home Office to the Ministry of Housing, Communities and Local Government (MHCLG) as of 1 April 2025. MHCLG now intends to take forward the necessary legislation to implement these changes. 

2.9 MHCLG officials will continue to work closely with LGA colleagues to provide guidance to support FRAs to implement the final changes and to monitor the implementation of these changes to ensure they are delivered effectively.  

3. Proposed amendments to the Firefighters Pension Scheme (England) Order 2006 

3.1 This chapter considers the responses to the proposals, taking each consultation question in turn.   

Q1. Do you agree that the proposal for missed pension lump sum payments for deceased individuals achieves the stated policy objective?  

3.2 The missed pension lump sum payment would provide any pension lump sum that a deceased individual would have received if they had been able to elect to join the modified scheme prior to their death. The payment would be paid to the deceased’s survivor or estate, 

3.3 A total of 43 responses were received. 27 agreed with the proposal, while 16 disagreed. 

Summary of responses to question 1: 

3.4 While the majority of respondents supported the proposal, the following points were raised about specific aspects of the draft provisions:  

• Commutation assumption: A common concern was the absence of an assumption that the deceased member would likely have commuted 25 percent of their annual pension for a pension lump sum payment. Respondents noted that including this assumption would, in most cases, result in a higher lump sum for beneficiaries or the estate. 

• Opt-out periods/conversion of standard service: Clarification was requested on whether periods during which the deceased had opted out of the 2006 Scheme would be included in the calculation. Clarification was also sought on whether an allowance would be made to allow any of the deceased’s standard 2006 Scheme service to be converted to special service. 

• Incomplete service or pay records: Some responses highlighted the lack of provisions for cases where FRAs cannot determine the deceased’s service period or where pay records are missing. It was suggested that assumptions should be permitted in such cases. 

• Access to employment information: Concerns were raised about the ability of beneficiaries to access the necessary employment information to support an application. Greater flexibility was requested in such cases. 

• Interest and pensions increase: Respondents asked whether interest would be applied to any employee contributions owed by the deceased, and whether pensions increase would be factored into the missed pension lump sum. 

• Coverage of specific cases: One respondent noted that the draft provisions may not clearly cover individuals with retained service between 7 April 2000 and 6 April 2006 who died before the 2014 Options exercise. It was unclear whether these individuals would be eligible. 

Government response to question 1: 

3.5 The government agrees that it is reasonable to assume that those deceased individuals who would have been entitled to receive special pension payments prior to their death would have elected to commute the maximum of their annual pension for a retirement lump sum. This is based on the generosity of the special commutation factors and on the experience of the 1992 Scheme. For these reasons, this assumption will be incorporated into the calculation of the missed pension lump sum.  

3.6 Any periods that the deceased had opted out of the standard 2006 Scheme will be included for the purpose of calculating the missed pension payment and any additional contributions (to include interest) owed by the deceased member will also be factored into the calculation. Interest will be applied to the contributions owed by the deceased; in the same way it is applied to contributions owed by a member.  

3.7 The amended provision will not allow for the conversion of any of the deceased’s standard 2006 Scheme service to special service. The deceased’s standard 2006 Scheme benefits will have already crystallised at the time of the member’s death and be in payment/have been paid. This will avoid the need to recover pension that has already been paid to survivor beneficiaries. 

3.8 For those individuals who are eligible to submit an application to receive a missed pension payment, it is acknowledged that members may not have access to all the detailed information on the deceased’s employment. To address concerns about incomplete information, a more flexible application process will be introduced.  

3.9 Applicants will need to submit as much information as possible. However, some evidence of entitlement must be provided. For any missing information about the deceased’s employment, the provision will be extended so that an FRA can determine the deceased’s service dates and pay from records they hold or estimate using their local experience. Where this is not possible, or where any estimate results in the deceased’s retained pensionable pay to be less than 25% of the pensionable pay of a whole-time-equivalent regular firefighter employed in a similar role with equivalent qualifying service, FRAs will have the discretion to apply the assumption that the deceased’s retained pensionable pay was 25 percent of a whole-time-equivalent regular firefighter for their period of employment as a retained firefighter. This reflects the flexibilities introduced previously for the purchase of service during the extended limited period.   

3.10 Finally, the provision will cover individuals with retained service between 7 April 2000 and 6 April 2006 who died before the 2014 Options exercise, provided they meet the qualifying criteria. 

Q2. Do you agree that the proposal to provide a survivor’s missed pension lump sum payment achieves the stated policy objective? 

3.11 The survivor’s missed pension lump sum payment would provide a lump sum payment to the survivor beneficiaries of any deceased individual where a missed pension lump sum payment is made. It is intended to reflect the life-time value of the survivor’s pension entitlement. 

3.12 A total of 41 responses were received for this question. Of these, 26 agreed that the proposal met the stated policy objective, while 15 disagreed. 

Summary of responses to question 2: 

3.13 While the majority of respondents supported the proposal, the following points were raised: 

• Opt-out periods: Clarification was requested on whether periods during which the deceased had opted out of the standard 2006 Scheme would be included in the calculation.  

• Scope of beneficiaries: Some respondents raised concerns that the draft provisions allowed for payments to be made to general estate beneficiaries in the absence of a surviving spouse or children. This was seen as extending beyond the scope of the original proposal. 

• Assumptions on pay: Concerns were raised that the draft provisions did not allow FRAs to make assumptions about pensionable pay where records were missing or incomplete. It was suggested that, in such cases, an assumed pay level equivalent to at least one-quarter of a whole-time-equivalent firefighter’s pay should be used. 

• Formula transparency: Several responses requested greater clarity on how the survivor’s missed pension lump sum formula was derived. 

• Interest inclusion: One response noted that while the consultation document stated interest would be included in the calculation, this was not reflected in the draft formula.

• Pre-July 2000 service: One response highlighted that the formula only accounted for service from July 2000 onwards, potentially excluding earlier service from the calculations. 

Government response to question 2:  

3.14 The government has agreed that periods during which the deceased had opted out of the standard 2006 Scheme will be included in the calculation of the survivor’s missed pension lump sum payment. The employee contributions owed by the deceased for these periods of opt-out service will also be factored into the calculations accordingly in the same way as for any other members who purchase this service, 

3.15 The survivor’s missed pension lump sum payment should only be payable to eligible surviving beneficiaries and are not intended to be paid to other beneficiaries of the estate as the current draft provision permits. Therefore, the draft provision will be amended so that eligibility for the survivor’s missed pension lump sum payment will only apply to eligible survivors. 

3.16 The government recognises that there may be cases where an FRA may be required to estimate the pay and service of the deceased. This is because they are unable to determine the pensionable service of a deceased member from existing records or information provided by the FRA or the applicant. The government will introduce additional flexibility for these cases or where an estimate results in a determination that the member’s retained pensionable pay is less than 25 percent of the pensionable pay of a whole-time equivalent regular firefighter in a comparable role with equivalent service. FRAs will be permitted to apply a default assumption that the deceased’s retained pensionable pay was 25 percent of a whole-time-equivalent regular firefighter for the relevant period of employment. This approach aligns with the flexibilities previously introduced for purchasing service during the extended limited period. 

3.17 During the 2014 options exercise, a special death grant was introduced for retained firefighters who died in service between 1 July 2000 and 5 April 2006. This grant was set at 2.5 times pensionable pay. For the 2023 options exercise, an extra payment was added for service before 2000. Survivors receive an additional lump sum of 0.1 times pensionable pay for each year of service before 2000. This amount was based on GAD’s estimate of how the value of these benefits increases for firefighters who started work in earlier decades. 

3.18 GAD’s estimate considered typical survivor pensions for different groups of firefighters who might have died in service between 2000 and 2006. They then converted these pensions to what would be paid as a one-off lump sum, rather than receiving it as regular payments. The calculation did not include any interest for the time between the firefighter’s death and the payment being made. Using this approach keeps the rules simple and in line with the original death grant from the first exercise. In practice, a calculation for each individual deceased firefighter’s exact circumstances could be a higher or lower than the 0.1 times rate. 

3.19 This method was also chosen at the start of the 2023 options exercise as a fair way to pay survivors of existing special members who died before they had a chance to buy pre 2000 pension. This includes those retained firefighters who participated in the 2014 options exercise but could not take part in the 2023 exercise because they died beforehand. 

3.20 The consultation suggested allowing all firefighters who died before being able to buy extra service in the 2023 exercise to be covered, no matter how or whether they participated in the 2014 options exercise. Extending the 0.1 times rule makes it easy and consistent to give survivors a lump sum that reflects the firefighter’s past service and final pay, alongside any other death benefits already provided by the 2006 scheme. 

3.21 The same approach taken for grants paid during the 2014 options exercise will be used where someone had died prior to being able to join the modified scheme. This means no interest will be considered for the time between the deceased’s death and date of lump sum payment. 

3.22 Survivor’s benefits for service prior to 1 July 2000 are already covered by existing provisions such as the ‘additional death grant’ and ‘death grant for extended period’, subject to satisfying the eligible criteria. Therefore, the survivors missed pension lump sum payment will only apply to service from 1 July 2000 onwards. 

3.23 To avoid duplication, periods of eligible historic employment not purchased under the second options exercise will only be reflected once across all survivor lump sum payments. Therefore, where an ‘additional death grant’ is payable in respect of a deceased’s service on or after 1 July 2000, the ‘survivor’s missed pension lump sum payment’ is not payable. 

Q3. Do you agree that the proposal to extend the eligibility criteria for the ‘additional death grant’ achieves the stated policy objective? 

3.24 The proposal would extend the eligibility criteria for the additional death grant so it is also payable in respect of any deceased individual who did not join the modified scheme during the 2014 Options exercise and would have had an entitlement to join during the 2023 Options exercise, but they died prior to being able to make an election to join. 

3.25 A total of 43 responses were received for this question. Of these, 34 agreed that the proposal met the stated policy objective, while 9 disagreed. 

Summary of responses to question 3:  

3.26 While most respondents supported the proposal, one key point was raised: 

• Scope of the formula: Some respondents noted that the formula in Part 5, Rule 1C of the draft amendment legislation calculates the additional death grant based solely on service prior to July 2000. It was suggested that this approach does not adequately address cases where the deceased also had service on or after 1 July 2000 but had not joined during the 2014 options exercise. 

Government response to question 3: 

3.27 The government acknowledges that the formula for the additional death grant does not account for service on or after 1 July 2000 in cases where the deceased had not joined during the 2014 Options exercise. To correct this, the formula in Part 5, Rule 1C will be amended so that any additional death grant paid in respect of these individuals also reflects eligible service accrued by them on or after 1 July 2000. 

Q4. Do you agree that the proposal to extend the conversion options for ‘special deferred members’ achieves the stated policy objective? 

3.28 This proposal would extend the conversion options in the modified scheme to include those individuals who joined the modified scheme as special deferred members.   

3.29 A total of 43 responses were received for this question. Of these, 31 agreed that the proposal met the stated policy objective, while 12 disagreed. 

Summary of responses to question 4: 

3.30 While most respondents supported the proposal, one point of clarification was raised: 

• Eligibility clarification: One response sought clarification on whether individuals with standard service in the 2006 Scheme who left employment between ages 55 and 60, without taking early retirement, would be eligible to convert their service and receive retrospective payment of their special pension from the date of leaving. 

Government response to question 4: 

3.31 The government would like to clarify the change will allow individuals who join the modified scheme as special deferred members to convert any continuous standard service to special service. Where such individuals left employment where they were accruing standard 2006 Scheme service after attaining age 55, they will become entitled to immediate and retrospective payment of their special pension from the date they left their employment.   

Q5. Do you agree that the proposal to amend formula at Part 5, Rule 1B(8) to change the reference from ‘additional death grant’ to ‘extended death grant’ achieves the stated policy objective? 

3.32 This proposal would change the reference to ‘additional death grant’ to ‘extended death grant’ in the formula for calculating the extended death grant to avoid any confusion. 

3.33 All 43 respondents agreed that the proposed amendment met the stated policy objective. No issues or concerns were raised in relation to this proposal.  

Government response to question 5: 

3.34 In light of the unanimous support received, the government is content to proceed with amending the reference to ‘extended death grant’. 

Q6. Do you agree that the proposal to allow individuals to purchase any period/s of opted out standard service as special service achieves its stated objective? 

3.35 This proposal would allow members who joined the standard 2006 Scheme and who subsequently opted out prior to April 2015 to purchase the periods of opted out service as special service in the modified scheme. 

3.36 A total of 42 responses were received for this question. Of these, 33 agreed that the proposal met the stated policy objective, while 9 disagreed. 

Summary of responses to question 6: 

3.37 While the majority supported the proposal, several points were raised: 

• Eligibility clarification: One response sought clarification on whether individuals who transitioned from retained to a whole-time regular firefighter role before opting out of the 2006 Scheme would be eligible to purchase the opted-out period as special service. 

• Timing of entitlement: One response questioned the practicality of the requirement in Part 15, Rule 7(7), which mandates that the authority must pay the additional entitlement within three months of an application. It was noted that this may not be workable for individuals still in employment or those with a special deferred pension. 

• Access to purchase option: Another response raised concerns about the requirement in Part 15, Rule 1(b), which states that individuals must have already purchased an entitlement as a special member before the legislation comes into force in order to be eligible to purchase opted-out service. It was suggested that this would exclude those who had not previously had the opportunity to do so under the Matthews remedy. 

Government response to question 6: 

3.38 The government would like to clarify that individuals who joined the standard 2006 Scheme as a retained firefighter and changed their employment to a whole-time regular firefighter before opting out of the scheme membership will not be eligible under this provision. This proposal applies only to those who joined the standard 2006 Scheme and then subsequently opted out for any period of retained service prior to 1 April 2015. 

3.39 The policy intention is to also include individuals who have not joined the modified scheme previously, and also to individuals who are not currently in receipt of a pension.   

3.40 It is also intended that eligible individuals who, following a first Matthews options exercise election, ceased the payment periodic contributions early should be able to purchase any limited period service not bought by their original Matthews periodic contributions arrangement. 

Q7. Do you agree the proposal to extend flexibility for payments relating to new provisions achieves its stated policy objective? 

3.41 This proposal would allow the new pension awards introduced under this consultation to be made by 31 March 2026. 

3.42 All 43 respondents agreed that the proposal met the stated policy objective. No issues or concerns were raised in relation to this proposal. 

Government response to question 7: 

3.43 The government recognises that the delay in finalising this consultation and introducing the amending legislation has reduced the level of flexibility originally intended for making payments under the new provisions. 

3.44 To ensure that FRAs have sufficient time to implement these changes and to ensure that members do not unintentionally miss out on remedy or lack the time they need to make informed decisions, the government will amend the proposal and legislation will be introduced to allow a 12-month window, starting from the date the amendments come into force, during which these payments can be made. 

Q8. Are there any adverse consequences that we might not have considered of extending the closing date of the 2023 options exercise to 31 March 2026? 

3.45 This question relates to the proposal to extend the closure of the 2023 options exercise by 12 months to 31 March 2026. 

3.46 A total of 44 responses were received. Of these, 29 indicated that there were potential adverse consequences that had not been considered, while 15 confirmed that they did not foresee any such consequences.  

Summary of responses to question 8: 

3.47 The following concerns were raised: 

• Interest on contributions: Several respondents noted that extending the closing date could result in higher interest charges for individuals purchasing special service, as interest would continue to accrue. It was suggested that interest should be frozen as of 31 March 2025—the original deadline—or that any additional interest incurred due to the delay should be reimbursed through the Matthews compensation scheme. 

• Delays in implementation: One response expressed concern that the extension could lead to further delays by FRAs in implementing the Matthews remedy. It was also suggested that a 12-month extension may be excessive, particularly as many affected individuals are approaching retirement. 

• Support for complex cases: A respondent highlighted the absence of a finalised process for referring complex cases to the GAD. They emphasised the need for timely guidance and updates to calculators to support FRAs in recalculating benefits for pensioner and deferred members. 

• Coverage gaps: Some responses noted that the consultation did not address individuals who transitioned from retained to whole-time regular firefighter roles prior to 7 April 2000. 

• Unequal notification periods: Concerns were raised that individuals who received their notification before 1 April 2025 would not benefit from the extended timeframe, potentially giving them less time to make an informed decision compared to those notified after that date. 

• Extension of related provisions: One response suggested that the extension should also apply to other areas of the 2023 Options exercise, where appropriate. 

Government response to question 8: 

3.48 A key proposal in this consultation is to extend the closing date of the 2023 options exercise from 31 March 2025 to 31 March 2026. Under current scheme regulations, individuals must make their election by 31 March 2025. The government recognises that some individuals received their remedy offers close to this deadline and may not have had sufficient time to make an informed decision. 

3.49 To address this, the government will legislate to allow a 12-month extension from the date the amending legislation comes into force. This will ensure that individuals who have not had an opportunity to make an election for remedy prior to 31 March 2025, will still have an opportunity to do so, once the amendment take effect. This approach not only gives FRAs sufficient time to implement the changes but also ensures that members are not unintentionally excluded from remedy and have the time they need to make informed decisions. 

3.50 Interest will continue to be applied on employee contributions owed by individuals who elect to join the modified scheme during the extended period. This maintains a fair balance between the interests of eligible individuals, current scheme members, and the taxpayer. 

3.51 During the 2023 options exercise, a small proportion of cases with more complex circumstances will need to be referred to GAD. In July 2024, GAD issued a manual cases process update, which had requested FRAs to begin collating the necessary data for these referrals. A live trial began the following month to help develop the manual cases process. GAD subsequently invited all FRAs with collated data to securely refer these cases, as communicated in the LGA’s monthly bulletins for October 2024 and January 2025. In July 2025, GAD updated the manual case process with further information for FRAs and will provide further updates over the remainder of the 2023 options exercise. 

3.52 For these more complex cases, GAD will need to verify that FRAs have provided correct and complete information. Where necessary, GAD will liaise with officials to ensure consistency with policy intent. While GAD aims to process cases as quickly as possible, adequate time is needed to ensure accurate and consistent advice is provided to FRAs.  

Q9. Do you agree that the proposal to allow special pensioner members who are in receipt of a ‘member initiated early retirement’ pension to convert standard service to special service achieves the stated policy objective? 

3.53 This proposal would extend the provision to allow conversions for members who join the modified scheme as special pensioner members in receipt of a member initiated early retirement pension. 

3.54 A total of 42 responses were received for this question. Of these, 39 agreed that the proposal met the stated policy objective, while 3 disagreed.   

Summary of responses to question 9: 

3.55 While the majority supported the proposal, some respondents raised one key concern: 

• Scope of eligibility: Several responses noted that the draft provision did not extend to individuals who are in receipt of a deferred standard pension, or who have an entitlement to a deferred pension that has not yet come into payment. Respondents suggested that these individuals should also be allowed to convert their standard service to special service. 

Government response to question 9: 

3.56 The government acknowledges that the provision as originally drafted, did not cover individual entitled to join the modified scheme as special pensioner member who are either in receipt of a standard deferred pension or has an entitlement to one that has not yet been put into payment. 

3.57 In response to this feedback, the government has decided to proceed with the proposed amendment but to extend the scope of the provision. The revised provision will now also apply to:   

• Individuals who are currently in receipt of a standard deferred pension; and 

• Individuals who have an entitlement to a standard deferred pension which has not yet come into payment. 

3.58 This change ensures that all eligible individuals in these circumstances are appropriately covered under the modified scheme. 

Q10. Do you anticipate any equality issues arising from the implementation of the proposals in this consultation? 

3.59 A total of 41 responses were received. Of these: 19 respondents indicated that they anticipated potential equality issues arising from the proposals; 10 respondents stated that they did not anticipate any equality issues; and 12 respondents were unsure. 

Summary of responses to question 10: 

3.60 A number of responses highlighted the absence of an Equality Impact Assessment (EqIA) published alongside the consultation. Respondents noted that without such an assessment, it is difficult to determine whether the proposals could have adverse impacts on individuals with protected characteristics. 

Government response to question 10: 

3.61 Aside from the comments specifically relating to the EqIA, all other points raised in response to this question have been addressed in the government’s responses to earlier questions.  

3.62 The government has updated the EqIA originally published as part of the 2023 Retained Firefighters’ Pensions consultation outcome. This revised assessment will be published alongside this government’s response and considers both the size and profile of the groups directly affected by the consultation outcome, with reference to the wider population eligible for the second options exercise.  

Q11. Do you agree that the proposed changes effectively address the issues that have been identified in this consultation? 

3.63 A total of 42 responses were received. Of these 13 respondents agreed that the proposed changes effectively address the issues identified; 22 disagreed; and 6 were unsure. 

Summary of responses to question 11: 

3.64 Several key concerns were raised: 

• Application process for beneficiaries: A number of responses highlighted that beneficiaries applying for a missed pension payment on behalf of a deceased individual may not have access to full employment details, such as service dates and pensionable pay. It was suggested that the application process should be less prescriptive to accommodate this. 

• Support for families of deceased firefighters: One response suggested that further remedy may be needed to support families of firefighters who died between April 2000 and April 2006. 

• Value of missed pension payments: One respondent stressed the importance of ensuring that the missed pension payments are equivalent in value to what the deceased would have received had they been able to join the modified scheme. 

3.65 Other points raised in response to this question have already been addressed in the government’s responses to earlier questions. 

Government response to question 11: 

3.66 The government recognises that beneficiaries may not always have access to complete employment information when applying for a missed pension payment. To address this, a more flexible approach has been adopted: beneficiaries may submit any information they have available, and FRAs will be responsible for providing any missing details.  

3.67 As outlined in earlier responses, MHCLG have commissioned GAD to provide support to FRAs through the Matthews calculator and, where applicable, the manual cases process. These tools will be updated to reflect final policy decisions and regulations. Development has progressed alongside this consultation, and the calculator will be made available as soon as possible after the regulations are laid.  

3.68 For retained firefighters who died in service between 7 April 2000 and 5 April 2006, their survivors are already entitled to receive a death grant for the extended period.   

3.69 The missed pension lump sum must be calculated in line with the approach used for special pensioner members, adjusted to reflect the cessation of pension at the member’s death. As outlined in earlier responses, GAD will expand the Matthews calculator calculations and where relevant the manual cases process to support FRAs implementing these changes. 

4. Equalities impact 

4.1 The Public Sector Equality Duty (PSED) is set out in section 149 of the Equality Act 2010 and requires public authorities, in the exercise of their functions, to have due regard to the need to:  

• eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the 2010 Act; 

• advance equality of opportunity between people who share a protected characteristic and those who do not; and 

• foster good relations between people who share a protected characteristic and those who do not. 

4.2 This involves having due regard to the need to:  

i. remove or minimise disadvantages suffered by people due to their protected characteristics; and  

ii. take steps to meet the needs of people from protected groups where these are different from the needs of other people. 

4.3 The equality duty covers the nine protected characteristics: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex (gender) and sexual orientation.  

4.4 The government has considered the potential impact of the changes on people with protected characteristics in the Equality Impact Assessment, and has also engaged with fire sector employer and employee representatives on potential risks of adverse impacts in relation to groups with protected characteristics.  

4.5 The government has not identified any adverse impacts on groups with protected characteristics, as all members in scope for the remedy will have equal access to the remedy, irrespective of any protected characteristic that may apply to them. The eligible population is substantially older than the current retained workforce, reflecting the historic period of service required for eligibility. The Mathews remedy, and the impending changes from this consultation, intends to put those eligible retained firefighters into a position whereby they are provided similar benefits as those provided by the 1992 Scheme.   

4.6 The government has produced an Equality Impact Assessment for the groups affected by these proposed amendments that is published alongside this response. This assessment is compatible with the Equality Impact Assessment for the 2023 consultation and The Firefighters’ Pension Schemes (England) (Amendment) Order 2023 (SI 2023/986).