Consultation outcome

Amendments to Firefighters’ Pension Scheme – member contribution structure: equalities impact assessments

Updated 8 December 2025

1. Title and Outline of issue under consideration

Amendments to The Firefighters’ Pensions Regulations 2014: Proposed updates to member contribution structure

This EIA has been drafted to consider the equality implications of the proposed contribution rates changes arising from the Firefighters Pension Scheme contribution consultation in England.

These changes are necessary to ensure that the overall contribution yield meets the requirements set out following the most recent scheme valuation, maintaining the financial sustainability of the Firefighters’ Pension Scheme (FPS).

The proposed changes to the FPS member contribution structure are as follows:

• Retaining the tiered structure with an additional tier: The existing tiered structure for employee contribution rates will be retained, but with an additional tier, updated pay thresholds and modified gaps between different rates.
• Switch from WTE to Actual Pensionable Pay: Member contribution tiers will be determined on Actual Pensionable Pay. The appropriate contribution rate will be applied 1st April and there will be flexibility to change this if there is a material change. For members with multiple employment contracts (e.g. wholetime and retained roles), each contract will be assessed separately. This was seen as more equitable, particularly for part-time and retained firefighters (where monthly pay fluctuates), as it better reflects actual earnings and aligns with the principles of the CARE (Career Average Revalued Earnings) scheme.
• Automatically increase employee contribution rate thresholds in line with the consumer price index (CPI) every year. This is to provide a future-proofing mechanism to keep pace with pay increases and align with other public service pension schemes.

These changes are designed to:

• Ensure the overall contribution yield meets the requirements set out by the most recent scheme valuation.
• Support fairness and equity, particularly for part-time firefighters and those with variable working patterns.
• Maintain the financial sustainability of the FPS while supporting fair and inclusive outcomes.

This EIA will analyse the potential impacts of the first two changes - increasing tier thresholds and the transition to using actual pay - on those with protected characteristics.

To formally implement any changes resulting from the consultation, determinations made under the Firefighters’ Pension Scheme (England) Regulations 2014 will be amended.

The FPS is open to all firefighters, regardless of rank, age, race, sex, or any other protected characteristic. It provides the same generous benefits to every member, ensuring fairness and consistency across the workforce. All the proposed changes will apply consistently across salary tiers, regardless of a member’s identity.

This inclusive approach reflects the scheme’s commitment to equality and supports firefighters throughout their careers with robust and reliable pension provisions.

2. Summary of the evidence considered in demonstrating due regard to the Public Sector Equality Duty.

• Government Actuary’s Department – Proposed updates to member contribution structure.
• Fire and rescue workforce and pensions statistics: England, year ending March 2024 - GOV.UK
• The employment of disabled people 2024 (updated on 20 June 2025) The employment of disabled people 2024 - GOV.UK
• Question 6 of the consultation document that asked for PSED considerations

3. Consideration of aim 1 of the duty: eliminate unlawful discrimination, harassment, victimisation, and any other conduct prohibited by the Equality Act 2010

3.1 Age

The potential impact of the new proposals on members of all ages has been considered.

The 2015 Scheme uses a Career Average Revalued Earnings (CARE) approach based on pensionable pay throughout the member’s career. As a result of this, the proposal of moving to contribution rates based on Actual Pensionable Pay is more appropriate for determining contributions for a CARE scheme for members of all ages. In a CARE scheme, each year’s pension accrual is based on the member’s actual pensionable earnings for that year, rather than their final salary. This means contributions should ideally mirror the same principle—being proportionate to what the member earns at any given time.

Age as at 1 April 2024	Tier 1 (11.0%)	Tier 2 (12.9%)	Tier 3 (13.5%)	Tier 4 (14.5%)
17-24	Nil	100%	Nil	Nil
25-34	Nil	99%	1%	Nil
35-44	Nil	91%	9%	<1%
45-54	Nil	80%	20%	<1%
55+	Nil	86%	13%	1%

Under the current structure, no members fall into Tier 1 across any age group. Most members are in Tier 2, with a greater proportion moving into Tier 3 from age 45 onwards. A small number of members are in Tier 4.

The proposed structure includes higher pay thresholds for the contribution tiers, which results in more members (particularly younger members) with lower Actual Pensionable Pay now falling into the lowest contribution tier.

The proposed changes to the member contribution structure will apply to all members regardless of their age.

3.2 Change 1: Additional Tier – Impact on Age:

3.3 Direct Discrimination

We have not identified any evidence to suggest that an additional tier of the member contribution structure directly discriminates on the basis of age. This change applies to every member regardless of age.

3.4 Indirect Discrimination

The statistical analysis to support the EIA, provided by the Government Actuary’s Department (GAD), is published alongside this assessment. The chart above, produced by GAD, demonstrates that younger members, specifically those aged 17-24 and 25-34, will contribute a lower percentage on average under the proposed structure compared to the current structure. Members in the age bracket 35-44 will on average pay a slightly higher percentage than under the current structure, and those aged 45-55 and 55+ will on average pay a higher percentage than under the current structure.

This reflects younger members typically earning less since they are at the beginning of their careers, as can be seen by high percentages of members in younger age brackets placed in lower contribution tiers under the proposed structure. The inverse is also true, reflecting that older members earn more, on average. The increase becomes more notable from age 45 onwards.

The government’s justification for these impacts is that the structure is not based on age, but on earnings, and therefore differential impact by age is a reflection of differential earnings at different points in a member’s career. It is rational that a pension scheme would expect a member who is paid more to contribute more, as most public service pension schemes do. Therefore, any impact by age is objectively justified by the fact that the contribution rates are based on earnings and it is done to achieve a fairness across the tiers.

3.5 Change 2: Switch from WTE Pay to Actual Pensionable Pay– Impact on Age:

3.6 Direct Discrimination

We have not identified any evidence to suggest that using actual pay rather than WTE pay directly discriminates on the basis of age.

3.7 Indirect Discrimination

We do not consider there to be any indirect discrimination on the basis of age.

The change away from whole-time equivalent pay would be particularly beneficial for members such as part-time and retained firefighters. This change ensures contributions are directly aligned with what each member earns rather than requiring them to pay a higher proportion of their actual earnings as pension contributions compared to their full-time counterparts, which is currently the case.

The proposed changes to the contribution rates or structure will apply equally to all eligible firefighters, regardless of age.

3.8 Change 3: Automatically increase pay thresholds in line with the consumer price index (CPI)

3.9 Direct Discrimination

We have not identified any evidence to suggest that automatically increasing pay thresholds in line with CPI directly discriminates on the basis of age.

3.10 Indirect Discrimination

We do not consider there to be any indirect discrimination on the basis of age. A CPI increase would be applied evenly to all contribution thresholds, both to the lower thresholds (where more younger members will be) and to higher thresholds (where more older members will be).

By using CPI to increase contribution thresholds, instead of using pay awards, there is potential for pay awards to deviate from inflation, which may distort which members are in which contribution tiers, depending on the pay award. For example, if a pay award was more generous to lower paid staff (and therefore younger members), more younger staff could potentially fall into the next contribution band. The government considers this a consideration for the pay award, and not for the pension scheme.

3.11 Disability

The potential impact of the new proposals on members with any form of disability has been considered.

Firefighter workforce statistics as of March 2024, shows that 5% of firefighters in England declared that they had a disability. We do not have available data on what these members are paid, and therefore what pension contribution they pay, nor if they are part-time/retained or whole-time.

3.12 Change 1: Additional Tier– Impact on Disability:

3.13 Direct Discrimination 

We have not identified any evidence to suggest that an additional tier of the member contribution structure directly discriminates on the basis of disability.

3.14 Indirect Discrimination

There is no evidence that an additional tier will indirectly disadvantage firefighters with disabilities. Contributions are not determined by disability status, and statutory protections remain in place.

3.15 Change 2: Switch from WTE Pay to Actual Pensionable Pay– Impact on Disability:

3.16 Direct Discrimination

We have not identified any evidence to suggest that using Actual Pensionable Pay assessed rather than the currently used WTE pay directly discriminates on the basis of disability.

3.17 Indirect Discrimination

We do not consider there to be any indirect discrimination on the basis of disability. The most recent DWP report regarding the employment of those with a disability, states that people with a disability were more likely than those without a disability to be working part-time (and subsequently fewer hours). Since the change away from whole-time equivalent pay would be particularly beneficial for members such as part-time and retained firefighters, there may be positive impacts for members with a disability.

The proposed changes to the contribution rates or structure will apply equally to all eligible firefighters, regardless of disability.

3.18 Change 3: Automatically increase pay thresholds in line with the consumer price index (CPI)

3.19 Direct Discrimination

We have not identified any evidence to suggest that automatically increasing pay thresholds in line with CPI has a direct discrimination on the basis of disability.

3.20 Indirect discrimination

We do not consider there to be any indirect discrimination on the basis of disability.

3.21 Gender Reassignment

The potential impact of the new proposals on members who are undergoing or have undergone gender reassignment has been considered.

It is important to note that sex and gender are two different concepts. A person’s gender identity is not always the same as the sex assigned to them at birth, and some people may not identify as having a gender or as non-binary.

Under the Equality Act 2010, gender reassignment is also a protected characteristic and the potential impact of these new proposals on this protected cohort has also been considered.

There is no data on members of the FPS that have undergone or are undergoing gender reassignment.

3.22 Change 1: Additional Tier – Impact on Gender Reassignment:

3.23 Direct Discrimination

We have not identified any evidence to suggest that an additional tier of the member contribution structure directly discriminates on the basis of gender reassignment.

3.24 Indirect Discrimination

There is no evidence that an additional tier will indirectly disadvantage firefighters on the basis of gender reassignment.

3.25 Change 2: Switch from WTE Pay to Actual Pensionable Pay– Impact on Gender Reassignment:

3.26 Direct Discrimination

We have not identified any evidence to suggest that using Actual Pensionable Pay rather than WTE pay directly discriminates on the basis of gender reassignment.

3.27 Indirect Discrimination

There is no evidence that using Actual Pensionable Pay, rather than WTE pay, will indirectly disadvantage firefighters on the basis of gender reassignment.

The proposed changes to the contribution rates or structure will apply equally to all eligible members, regardless of gender reassignment.

3.28 Change 3: Automatically increase pay thresholds in line with the consumer price index (CPI)

3.29 Direct Discrimination

We have not identified any evidence to suggest that automatically increasing pay thresholds in line with CPI has a direct discrimination on the basis of gender reassignment.

3.30 Indirect Discrimination

There is no evidence to suggest that automatically increasing pay thresholds in line with CPI has an indirect impact on the basis of gender reassignment. The CPI uplift will be applied equally to all members.

3.31 Marriage and Civil Partnership

The potential impact of the new proposals on members who are unmarried, married or in a civil partnership has been considered.

3.32 Change 1: Additional Tier – Impact on Marriage and Civil Partnership:

3.33 Direct Discrimination

We have not identified any evidence to suggest that an additional tier of the member contribution structure directly discriminates on the basis of marriage and civil partnership.

3.34 Indirect Discrimination

There is no evidence that an additional tier will indirectly disadvantage firefighters on the basis of marriage and civil partnership.

3.35 Change 2: Switch from WTE Pay to Actual Pensionable Pay – Impact on Marriage and Civil Partnership:

3.36 Direct Discrimination

We have not identified any evidence to suggest that using Actual Pensionable Pay rather than WTE pay directly discriminates on the basis of marriage and civil partnership.

3.37 Indirect Discrimination

There is no evidence that using Actual Pensionable Pay, rather than

WTE pay, will indirectly disadvantage members on the basis of marriage and civil partnership.

The proposed changes to the contribution rates or structure will apply equally to all eligible members, regardless of their relationship status.

3.38 Change 3: Automatically increase pay thresholds in line with the consumer price index (CPI)

3.39 Direct Discrimination

We have not identified any evidence to suggest that automatically increasing pay thresholds in line with CPI causes direct discrimination on the grounds of marriage and civil partnership.

3.40 Indirect Discrimination

There is no evidence to suggest that automatically increasing pay thresholds in line with CPI has an indirect adverse impact on the basis of marriage or civil partnership. The CPI uplift will be applied equally to all members.

3.41 Pregnancy and Maternity

The potential impact of the new proposals on members who take maternity or paternity leave has been considered.

3.42 Change 1: Additional Tier – Impact on Pregnancy and Maternity:

3.43 Direct Discrimination

We have not identified any evidence to suggest that an additional tier of the member contribution structure directly discriminates on the basis of pregnancy and maternity.

3.44 Indirect Discrimination

There is no evidence that an additional tier will indirectly disadvantage firefighters on the basis of pregnancy and maternity.

3.45 Change 2: Switch from WTE Pay to Actual Pensionable Pay– Impact on Pregnancy and Maternity:

3.46 Direct Discrimination

We have not identified any evidence to suggest that using Actual Pensionable Pay rather than WTE pay directly discriminates on the basis of pregnancy and maternity.

3.47 Indirect Discrimination 

Switching to Actual Pensionable Pay will apply equally regardless of whether someone is on any family related leave or not. The proposed changes to the contribution structure will apply equally to all eligible firefighters, regardless of pregnancy or maternity.

3.48 Change 3: Automatically increase pay thresholds in line with the consumer price index (CPI)

3.49 Direct Discrimination

We have not identified any evidence to suggest that automatically increasing pay thresholds in line with CPI has a direct discrimination on the basis of pregnancy or maternity.

3.50 Indirection Discrimination

None of the evidence available suggests there is indirect discrimination automatically uplifting pay thresholds in line with CPI on the basis of pregnancy or maternity.

3.51 Race

The potential impact of the new proposals on members of varying ethnic backgrounds has been considered.

Firefighter workforce statistics as of 31 March 2024 (where ethnicity information was provided), show 5.4% of firefighters were from an ethnic minority.

Fire and rescue workforce and pensions statistics: England, year ending March 2024 - GOV.UK

3.52 Change 1: Additional Tier – Impact on Race:

3.53 Direct Discrimination

We have not identified any evidence to suggest that an additional tier of the member contribution structure directly discriminates on the basis of race.

3.54 Indirect Discrimination

There is no evidence that an additional tier will indirectly disadvantage firefighters on the basis of race. Workforce statistics show firefighters (the lowest and most common rank of staff) was the only rank to show a percentage of staff that are from an ethnic minority (6.4%) higher than the all-firefighter figure of 5.4%. Therefore, on average doing lower grade jobs, and as such they are therefore on average paid less. Splitting the tiers out will therefore likely be beneficial, in a similar way to how it will be beneficial for younger members.

3.55 Change 2: Switch from WTE Pay to Actual Pensionable Pay – Impact on Race:

3.56 Direct Discrimination

We have not identified any evidence to suggest that using Actual Pensionable Pay rather than WTE pay directly discriminates on the basis of race.

3.57 Indirect Discrimination

There is no evidence that an additional tier will indirectly disadvantage firefighters on the basis of race.

3.58 Change 3: Automatically increase pay thresholds in line with the consumer price index (CPI)

3.59 Direct Discrimination

We have not identified any evidence to suggest that automatically increasing pay thresholds in line with CPI has a direct discrimination on the basis of race.

3.60 Indirection Discrimination

There is no evidence that automatically increasing pay thresholds in line with CPI indirectly discriminates members based on their race. The CPI uplift will apply to all members, regardless of race.

3.61 Religion or Belief

The potential impact of the new proposals on members with different religious beliefs has been considered.

3.62 Change 1: Additional Tier – Impact on Religion or Belief:

3.63 Direct Discrimination

We have not identified any evidence to suggest that an additional tier of the member contribution structure directly discriminates on the basis of religion or belief.

3.64 Indirect Discrimination

We do not currently hold data and are not aware of any evidence which indicates that an additional tier will indirectly disadvantage firefighters on the basis of religion or belief.

3.65 Change 2: Switch from WTE Pay to Actual Pensionable Pay– Impact on Religion or Belief:

3.66 Direct Discrimination

We have not identified any evidence to suggest that using Actual Pensionable Pay rather than WTE pay directly discriminates on the basis of religion or belief.

3.67 Indirect Discrimination

We do not currently hold data and are not aware of any evidence that indicates that using Actual Pensionable Pay, rather than WTE pay, will indirectly disadvantage firefighters on the basis of religion or belief.

The proposed changes to the member contribution structure will apply equally to all members regardless of their religion or belief.

3.68 Change 3: Automatically increase pay thresholds in line with the consumer price index (CPI)

3.69 Direct Discrimination

We have not identified any evidence to suggest that automatically increasing pay thresholds in line with CPI has a direct discrimination on the basis of religion or belief.

3.70 Indirection Discrimination

There is no evidence that automatically increasing pay thresholds in line with CPI has an indirection discrimination to members based on religion or belief. The CPI uplift will apply to all members, regardless of their religion or belief.

3.71 Sex

The potential impact of the new proposals on both male and female members has been considered.

Initial analysis of the 2024 data showed that c.91% of the active scheme membership were male, which is broadly consistent with the 2020 valuation data. It is therefore expected that there will be more male members impacted by an update to the member contribution structure than female members.

Firefighter workforce statistics as of 31 March 2024, show that female firefighters account for 9.3% of the workforce.

3.72 Change 1: Additional Tier – Impact on Sex:

3.73 Direct Discrimination

We have not identified any evidence to suggest that an additional tier of the member contribution structure directly discriminates on the basis of sex.

3.74 Indirect Discrimination

GAD analysis shows there is a small increase in the average contribution rate for males under the proposed structure, while there is a small decrease in the average contribution rate for females.

The small increase for males may be driven by their greater likelihood of working full-time or earning higher Actual Pensionable Pay, placing them in higher contribution tiers under the proposed structure. The male composition of the membership amplifies this effect.

3.75 Change 2: Switch from WTE Pay to Actual Pensionable Pay – Impact on Sex:

3.76 Direct Discrimination

We have not identified any evidence to suggest that using Actual Pensionable Pay rather than WTE pay directly discriminates on the basis of sex.

3.77 Indirect Discrimination

We do not consider there to be any indirect discrimination on the basis of sex. The most recent government statistics regarding women in employment states that 36% of women in employment worked part-time, compared with 14% of men. Females are more likely to work part-time and therefore tend to have lower Actual Pensionable Pay. The change to Actual Pensionable Pay places a greater proportion of females in lower contribution tiers under the proposed structure. Therefore, there may be positive impacts to female members, as switching to Actual Pensionable Pay is fairer to part-time workers. As previously mentioned, this ensures contributions are directly aligned with what each member earns rather than require them to pay a higher proportion of their actual earnings as pension contributions compared to their full-time counterparts, which is currently the case.

There are both male and female firefighters present at all levels, and the proposed changes will be applied consistently across the workforce, regardless of sex.

3.78 Change 3: Automatically increase pay thresholds in line with the consumer price index (CPI)

3.79 Direct Discrimination

We have not identified any evidence to suggest that automatically increasing pay thresholds in line with CPI has a direct discrimination on the basis of sex.

3.80 Indirection Discrimination

There is no evidence that automatically increasing pay thresholds in line with CPI has an indirection discrimination to members based on sex. The CPI uplift will apply to all members, regardless of sex.

3.81 Sexual Orientation

The potential impact of the new proposals on members of different sexual orientations has been considered.

3.82 Change 1: Additional Tier – Impact on Sexual Orientation:

3.83 Direct Discrimination

We have not identified any evidence to suggest that an additional tier of the member contribution structure directly discriminates on the basis of sexual orientation.

3.84 Indirect Discrimination

We do not currently hold data and are not aware of any evidence which indicates that an additional tier indirectly disadvantage firefighters on the basis of sexual orientation.

3.85 Change 2: Switch from WTE Pay to Actual Pensionable Pay – Impact on Sexual Orientation:

3.86 Direct Discrimination

We have not identified any evidence to suggest that using Actual Pensionable Pay rather than WTE pay directly discriminates on the basis of sexual orientation.

3.87 Indirect Discrimination

We do not currently hold data and are not aware of any evidence which indicates that using Actual Pensionable Pay, rather than WTE pay, will indirectly disadvantage firefighters on the basis of sexual orientation.

The proposed changes to the member contribution structure will apply equally to all members regardless of their sexual orientation.

3.88 Change 3: Automatically increase pay thresholds in line with the consumer price index (CPI)

3.89 Direct Discrimination

We have not identified any evidence to suggest that automatically increasing pay thresholds in line with CPI has a direct discrimination on the basis of sexual orientation.

3.90 Indirection Discrimination

There is no evidence that automatically increasing pay thresholds in line with CPI has an indirection discrimination to members based on the basis of sexual orientation, as the CPI uplift will apply to all members regardless of sexual orientation.

4. Consideration of aim 2 of the duty: Advancing equality of opportunity between people who share a protected characteristic and people who do not share it

Having due regard to the need to advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it involves having due regard to the need to:

• Remove or minimise disadvantages suffered by persons who share a relevant protected characteristic that are connected to that characteristic

The proposed changes to the member contribution structure, specifically the increase in salary tiers and the shift from using WTE pay to Actual Pensionable Pay, is intended to ensure that contributions are proportionate to earnings. This change helps to minimise disadvantage for retained firefighters or those working part-time (work-force statistics show this is more likely to be female). By basing contribution tiers on Actual Pensionable Pay rather than WTE, the policy better reflects individual circumstances and avoids disproportionately higher contributions for those working reduced hours.

• Take steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it

The revised contribution structure supports firefighters with protected characteristics by ensuring that access to the 2015 Fire Pension Scheme is maintained across the workforce. The scheme is recognised as generous and valuable, and the consistent application of contribution tiers ensures that all firefighters, regardless of role, working pattern, or personal characteristics, can participate fully and benefit from the scheme. The move to Actual Pensionable Pay also better accommodates retained firefighters who make up 26% of all firefighters.

• Encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately low

By ensuring that the 2015 FPS remains accessible and equitable, the proposed changes help to promote retention and progression within the fire service for all members. The benefits provided by the scheme, such as defined pension accrual and survivor benefits, are the same regardless of role, with only the pensionable salary varying.

5. Consideration of aim 3 of the duty: Fostering good relations between people who share a protected characteristic and persons who do not share it

The proposed changes are not expected to negatively impact relations between individuals who share protected characteristics and those who do not. The policy applies consistently and is based on role and responsibility rather than personal characteristics.

By maintaining a consistent approach and continuing to monitor representation and outcomes through the EIA process, the policy helps to promote understanding and foster good relations among diverse groups within the firefighter workforce.

6. Ongoing compliance with the PSED

We consider that it is not necessary to collate additional information specifically for this policy change, as the Equality Impact Assessment process is conducted in line with each scheme valuation cycle. This ensures that any potential impacts on individuals with protected characteristics are reviewed and assessed at appropriate intervals, in line with changes to scheme design and contribution structures.

The EIA process is designed to identify and evaluate any direct or indirect discrimination that may arise, as well as to assess the extent to which the policy advances equality of opportunity and fosters good relations between different groups. By using the most recent firefighter workforce data, we can monitor trends in representation and contribution outcomes across protected characteristics, including sex, race, and age.

We will remain engaged with member representatives throughout and after the implementation process, particularly to identify and address any potential areas where discrimination could occur. This ongoing dialogue will support transparency, responsiveness, and continuous improvement in how the contribution structure is applied.

Should any significant changes in workforce composition or policy context arise outside of the valuation cycle, we will revisit the need for additional data collection or interim assessment.

6.1 Review date:  

An exact review date cannot be provided at this stage, as the timing will be contingent upon the conclusion of the current scheme valuation by GAD, followed by any resulting consultation to amend the contribution rates. The review process will be initiated once these steps have been completed.

7. Section 55 duty (for immigration, asylum, and nationality considerations only)

This policy does not relate to immigration, asylum, or nationality functions therefore regard to the duty in section 55 of the Borders, Citizenship and Immigration Act 2009 is not needed.

8. Risks to vulnerable individuals and other groups

The proposed changes to the member contribution structure are not expected to create or exacerbate risks for vulnerable individuals or groups. The policy relates solely to internal contribution structures within the firefighter workforce and does not directly impact service delivery to the public or access to support services.

9. Declaration and sign off

I have read the available evidence, and I am satisfied that this demonstrates compliance, where relevant, with section 149 of the Equality Act 2010 and that due regard has been had to the need to eliminate unlawful discrimination, advance equality of opportunity and foster good relations.

SCS Name & Title: Michelle Warbis

Directorate/Unit: Local Government Finance, Local Tax & Pensions

Lead contact: Florence Harvey

Date: XX/11/2025