Consultation outcome

Amendments to The Firefighters’ Pension Scheme (England) Regulations – member contribution structure: government response

Updated 8 December 2025

Introduction and contact details

This document is the post-consultation report for the consultation paper ‘Amendments to the 2015 Scheme (England) Regulations 2014 (S.I. 2014/2848) - Proposed updates to Member Contribution Structure’, which was published on 20 November 2024 and closed to responses on 29 January 2025. This report summarises the responses, including how the consultation process influenced the final shape of the policy proposals consulted upon.

Further copies of this report and the consultation paper can be obtained by contacting at the address below:

Firefighter Pensions
Local Government Finance
Ministry of Housing, Communities and Local Government
2nd Floor, Fry Building 2 Marsham Street
London
SW1P 4DF

Email: firepensionsteam@communities.gov.uk

Alternative format versions of this publication can be requested from the Ministry of Housing, Communities and Local Government, using the above contact details.

Complaints or comments

If you have any complaints or comments about the consultation process, you should contact the Ministry of Housing, Communities and Local Government at the above address.

Background

Reformed public sector pension schemes were established by regulations made under section 3 of the Public Service Pensions Act 2013 (“the 2013 Act”). The reformed Firefighters’ Pension Scheme in England (the “2015 Scheme”) is set out in the 2015 Scheme (England) Regulations 2014. Since 1 April 2022, the legacy 1992 and 2006 Schemes are closed to future accrual, and all firefighters in England have the option to join the 2015 Scheme.

The 2013 Act provides departments with the authority to make regulations setting the member contribution rates and requires that any changes to these rates follow the specified process.

Public sector pension reforms rebalanced taxpayer and member contributions, ensuring the schemes’ costs are sustainable and fair in the long term. The contribution yields for the 2015 Scheme in England are outlined in the Heads of Agreement.

Meeting the member contribution yield in each valuation period is a vital aspect of the reformed scheme design. This mechanism prevents additional burdens on scheme employers, by identifying and addressing member contribution yield shortfalls.

Based on the current member contribution rate structure, the Government Actuary’s Department (GAD)’s project the yield for the firefighter’s pension scheme, over the 2020 valuation implementation period 2024 to 2027, to be 13.0% p.a. This is 0.2% p.a. lower than the target member contribution yield of 13.2% p.a. Therefore, action is needed to update the contribution structure to attain the target yield.

While the yield is a fixed percentage, there are a range of approaches that could be taken to ensure that 13.2% is collected on average from across the whole scheme membership. The simplest method is to ask each member to contribute a flat rate of 13.2%. An alternative is to share out the 13.2% requirement across the workforce by setting a scale of rates for members, according to their pensionable earnings, in line with the current four contribution tiers. This approach is known as ‘tiered contributions’ and is the method adopted across most public service pension schemes.

Tiering has allowed the 2015 Scheme to reduce potential financial barriers and encourage all firefighters to participate in the generous pension scheme, which is a major component of the firefighter’s reward package and gives firefighters the opportunity to make good quality provision for their retirement.

Tiering has helped to deliver the following shared priorities that underpin the current approach to member contributions:

• including protections for the lower paid
• minimising the risk of opt-outs from the scheme across the whole membership
• ensuring that the scheme remains sustainable and a valuable part of the reward package and affordable to all members.

The Department and the Firefighters’ Pensions Scheme Advisory Board (SAB), comprising trade union and employer representatives, remain committed to these principles.

This report summarises the responses to the consultation, including how the consultation process influenced the final policy position

The responsible authority for each public service pension scheme must ensure that the contribution yield is met by appropriate adjustments to member contribution rates.

As the 2015 Scheme has moved from a final salary to a career average revalued earnings (CARE) model, all active members will have built up CARE benefits for service from 1 April 2022. To ensure the cost of the 2015 Scheme is fairly distributed and affordable for all members, tiered contribution rates mean that higher earners pay proportionally more than lower earners to access the valuable benefits of the scheme.

The average member contribution yield of 13.2% was set out in the 2015 Scheme: Heads of Agreement of February 2012. Based on the current member contribution rate structure, the Government Actuary’s Department (GAD)’s calculations project the yield for the firefighter’s pension scheme, over the 2020 valuation implementation period 2024 to 2027, to be 13.0% pa.  This is 0.2% pa lower than the target member contribution yield of 13.2% pa. It is this fact that has prompted the action to ensure that the member contribution structure is updated to attain the target yield.  From 2022, all firefighters have accrued benefits in the 2015 scheme, so the current average member contribution yield of 13.0% in 2024 to 2027 reflect the contributions that all member pay to the 2015 scheme.  There is therefore no direct link between the proposals to amend member contributions and the costs of the McCloud / Sargeant remedy or the cost control mechanism.

The Home Office, which had responsibility for the 2015 Scheme at the time, consulted on how to meet the target yield from for a 10-week period commencing 20 November 2024 and closing on 29 January 2025. Views were sought from all interested parties on proposed changes to member contributions, with a view to continuing to encourage participation in the 2015 Scheme.

During the consultation period, government officials engaged with a variety of stakeholders. Two drop-in sessions were hosted to provide further clarity and support to stakeholders. The first session was virtual and was held on 10 December 2024. The second session was in-person, at the Local Government Association’s offices in London on 21 January 2025.

The aim of the sessions was to inform stakeholders about the key elements of the consultation proposals, ensuring stakeholders were given clarity on the context and details of the proposals and the opportunity to directly engage with the government on the proposals.

GAD provided support for this consultation, and illustrations of the impact of different structures on example members’ contributions and take-home pay can be found in Section 4 and in appendix A. The methodology used by GAD to calculate the expected member contribution yield is also summarised in appendix B. Engagement sessions were also conducted with a range of sector experts during the consultation period, in which further examples were requested by stakeholders.

Following the stakeholder engagement session held in December 2024, the government committed to producing further illustrative examples to support understanding of the proposed contribution structures. These examples were developed in response to specific feedback and queries raised by stakeholders during the session and through subsequent correspondence.

The additional examples are intended to complement those included in the consultation document and are based on the same data, assumptions, and modelling approach. They are designed to demonstrate the potential impact of alternative contribution structures on members’ take-home pay and the overall yield of the scheme, while also addressing concerns around fairness, opt-out rates, and administrative feasibility.

All examples are projected to achieve the target member contribution yield of 13.2% over the period from April 2026 – March 2027 The examples can be found in Annex A.

Responsibility for the policy transferred to the Ministry of Housing, Communities and Local Government in July 2025.

The consultation was an opportunity to consider potential changes to the current contribution structure. It included questions on the rates payable at each level, differences between rates in different tiers, pay tier boundaries, and the number of tiers. The aim was to ensure the scheme design is reflective of the current workforce and will meet the overall member contribution target yield for the scheme in each valuation round.

We sought views on amendments to the 2015 Scheme (England) Regulations 2014 to:

• Achieve the target yield over 1 October 2025 to 31 March 2027, and future valuation periods.
• Update the member contribution structure to encourage scheme participation and reduce opt-outs.
• Ensure the member contribution structure is administratively sustainable.
• Ensure we have given due regard to the Public Sector Equality Duty.

Having reviewed the responses to the consultation the government’s intention is to amend the regulations to meet the objectives of:

• Encouraging scheme participation by protecting lower-paid members from disproportionate increases;
• Supporting career progression by smoothing contribution increases on promotion;
• Ensuring administrative sustainability by aligning with practices in other public service schemes.

This will mean the yield is achieved as required by the Heads of Agreement and the government’s ambition of ensuring the scheme is sustainable and fair is achieved.

Summary of responses

The consultation on proposed updates to the 2015 Scheme member contribution structure was published on 20 November 2024 and closed on 29 January 2025. It sought views on how best to update the member contribution structure to meet the target yield, encourage scheme participation, ensure administrative sustainability, and comply with the Public Sector Equality Duty.

A total of 24 unique responses were received. These included submissions from Fire and Rescue Authorities (FRAs), employer representatives, pension administrators, payroll providers, member representative bodies, and individual scheme members. Responses were submitted via email and through structured response templates. All responses have been considered in full.

The consultation posed six specific questions, each inviting respondents to indicate a preferred option and provide supporting commentary. The questions covered the tier structure, the method for determining contribution thresholds, futureproofing mechanisms, administrative sustainability, alternative proposals, and equality considerations.

The majority of respondents supported retaining a tiered contribution structure, with a clear preference for introducing an additional tier and modifying the gap between tiers. This was seen as a fairer and more progressive approach that could reduce opt-outs and support career progression.

There was a variety of views expressed when considering the preferred option to determine a member’s contribution threshold. There was support for both the continued use of Whole-Time Equivalent (WTE) pay and for a shift to using actual pensionable pay based on the previous year – with more people supporting this approach without any adjustment. However, there were many responses that suggested an alternative, using actual pensionable pay along the same lines as other public sector schemes. Responses balanced administrative simplicity and fairness, particularly for part-time regular and retained firefighters.

Views on adjusting the contribution thresholds each year were more mixed, although there was broad support for the principle of updating thresholds. Almost half of the responses suggested aligning thresholds with pay awards, but many of those responses also suggested an alternative measure of Average Weekly Earnings (AWE). Around quarter of responses agreed with using the Consumer Prices Index (CPI).

Almost all respondents indicated that their preferred contribution structure would be administratively sustainable, with many noting that their payroll systems could accommodate the proposed changes with minimal disruption. Only the option to introduce a marginal contribution model raised questions about implementation.

In response to a question about alternative approaches, a number of suggestions were made. These included the introduction of a 50/50 option, similar to the Local Government Pension Scheme, a flat rate contribution model, and a simplified three-band structure aligned with tax thresholds. While many of the suggestions were outside the scope of the current review, they have been noted for future consideration.

There were a range of views about equality impacts, particularly in relation to part-time workers, lower-paid members, and those with protected characteristics. These views were considered in developing the Equality Impact Assessment published alongside this response.

The government is grateful to all those who took the time to respond to the consultation.

Responses to specific questions

Question 1: What is your preferred tiering option to determine a members contribution tier?

• Option 1: Increase tiers by known pay increases.
• Option 2: Add an additional tier and modify the gap between tiers.
• Option 3: Marginal system.

We received 23 responses to this question, of which 30% expressed a preference for Option 1, 61% expressed a preference for Option 2, 9% expressed a preference for Option 3. In general, respondents noted that there is no single ideal option, and that their preference was based on a balance of varied factors.

Option 1 was favoured for its administrative simplicity and ease of implementation, particularly in the context of existing payroll configurations. Respondents noted that it would maintain the current structure while achieving the required yield with minimal disruption and would have the least impact on those with the higher incomes.

The majority of the respondents supported Option 2. This approach was seen as more progressive and better aligned with other public service pension schemes, such as the Local Government Pension Scheme (LGPS).

Option 2 was considered to strike the balance between the administrative burden perceived in a marginal system, and to avoid increasing contributions for most members. It was noted that this could reduce opt-outs among lower-paid members and support career progression by smoothing contribution increases on promotion. Responses highlighted that this option would be administratively feasible, with many payroll systems already capable of accommodating additional tiers.

Option 3 received limited support. While some respondents viewed it as the fairest approach in principle - charging higher rates only on the portion of income above each threshold - many raised concerns about its complexity and the significant administrative burden it would impose.

A small number of respondents proposed alternative approaches, which are outlined further in response to Question 5.

Government Response

The government is grateful for the considered responses to this question and acknowledges the dedicated support for Option 2. The government recognises that while Option 1 offers simplicity, it does not address the structural issues that have contributed to opt-outs and promotion disincentives. Option 3, while equitable in theory, is not considered administratively viable at this time Having reviewed the evidence submitted, the government considers that Option 2 - adding an additional tier and modifying the gap between tiers - offers the most balanced and sustainable approach.

The table below sets out the contribution structure, which gives an expected yield d of 13.20% when implemented on 1 April 2026, in line with the target yield for the scheme.

Tier	Actual pensionable earnings thresholds	Contribution rate applied to actual pensionable earnings
1	Up to £36,130	11.09%
2	£36,131 to £ 45,407	12.59%
3	£45, 408 to £66,908	14.09%
4	£66,909 to £190,691	15.590%
5	£190,692 or more	17.09%

This option supports the key policy objectives of:

• Encouraging scheme participation by protecting lower-paid members from disproportionate increases;
• Supporting career progression by smoothing contribution increases on promotion;
• Ensuring administrative sustainability by aligning with practices in other public service schemes.

Question 2: What is your preferred option to determine a members contribution threshold?

• Option 1: WTE to determine which contribution rate a member will pay
• Option 2: Use the previous year’s pay to determine which contribution rate, without any adjustment at the end of each scheme year.
• Option 3: Use the previous year’s pay to determine which initial contribution rate as in Option 2, then adjust for actual pay at the end of the scheme year.

We received 21 responses of which 48% preferred Option 1, 24% preferred Option 2, 10% preferred Option 3 and 19% did not agree with any option.

Support for Option 1 was based on administrative simplicity and consistency with current practice. Respondents noted that it would avoid the need for retrospective adjustments and provide clarity for both members and payroll administrators. However, other respondents were clear that they did not support Option 1, because as a career-average scheme, there is no longer a relationship between WTE pay and the accrual of benefits.

Support for Option 2 was based on it being fairer particularly for part-time and retained firefighters, as it better reflects actual earnings and that part-time staff should not pay the same rate as a full-time employee.

Option 3 received more limited support, and in some cases because neither Option 1 nor Option 2 was preferred. Some respondents acknowledged its fairness, and that contributions should reflect actual pay so that both contributions and benefits reflect earnings.

Of the total respondents 43% mentioned an alternative approach, using actual pensionable pay, similar to other public sector schemes, such as the LGPS – which FRAs are familiar with already - taking a similar approach. It was suggested that this would be fairer, as it would consider actual pay rather than an approximation based on prior years. It was suggested that the scheme manager would be best placed to estimate what the actual pensionable pay should be.

Government Response  

The government has decided to adopt a contribution threshold model based on actual pensionable pay, with the flexibility to change the rate if there is material change.

This aligns the scheme with key features of the LGPS 2014 and Civil Service Pension Scheme. While we consulted on whether to apply actual pay or whole-time equivalent, and have now decided on actual pay, with flexibility to adjust when material changes to pay occur, the process we are adopting was not one of the options suggested in the consultation. However, this approach was mentioned by 43% of respondents, including the Local Government Association (LGA), which represents 44 Fire and Rescue Authorities (FRAs).

The Equality Impact Assessment (EIA) highlighted that using WTE pay could lead to indirect discrimination, particularly affecting part-time and retained firefighters—groups that include a higher proportion of women and other protected characteristics. By using actual earnings, contributions remain proportional to what members earn, reducing inequity across different working patterns.

Using actual pay helps avoid scenarios where members hesitate to seek advancement due to disproportionate contribution increases.

During engagement sessions, stakeholders expressed concerns that WTE-based contributions would penalise part-time and retained staff and create barriers to flexible working arrangements. Feedback strongly supported an approach that mirrors actual pay, aligning with fairness principles and avoiding unintended consequences.

Other major public service schemes, such as the NHS and Civil Service already base contributions on actual pensionable pay, not WTE. Aligning with these schemes promotes consistency across the public sector and will reduce complexity for members who move between schemes.

While previous year’s earnings provide stability, they do not reflect real-time changes such as promotions, allowances, or changes in working hours for retained firefighters. Monthly assessments allow discretion to adjust rates if there is a material change, ensuring contributions remain accurate and fair throughout the year.

Administration and implementation

While the LGPS sets contribution rates based on the pay period including 1 April, it also allows employers discretion to adjust rates during the year if there is a material change in employment or pensionable pay. The 2015 Scheme will similarly incorporate flexibility by assessing pay monthly, offering a more responsive and equitable model for members with variable earnings.

This assessment aligns with the LGPS approach, which calculates contributions based on 1st April and allows the employers discretion to adjust rate when there is material change. It also addresses concerns raised during the consultation about fairness and administrative feasibility, especially for part-time and retained staff.

FRAs already administer the LGPS for their support staff, so this is a process they are familiar with, and their systems should already be able to accommodate it. The options proposed in the consultation did not fairly address the fluctuations in retained firefighters’ salaries.

Employers must ensure contribution bands reflect members’ pensionable pay fairly and consistently. Adjustments should occur when there is a material change in pay that is expected to persist and significantly affects the member’s contribution band.

A material change is a permanent or long-term alteration in pensionable pay, such as, promotion or change in role resulting in a higher salary and Introduction or removal of a pensionable allowance.

Short-term or one-off fluctuations (e.g., overtime spikes, backdated pay awards paid in a single month) do not normally constitute a material change.

New approach to determine the contribution threshold

• Actual pay is key: The employer must assess the contribution rate for each job based on the actual pensionable pay the member receives. This includes the normal salary and pensionable allowances.
• Annual assessment: The employer determines the initial contribution rate at the start of each scheme year (April 1st) and for new joiners. This assessment typically considers your rate of pay at that specific date.
• Pay changes during the year: Employers should adjust contribution bands where a change in pensionable pay is permanent or expected to continue for the foreseeable future. Employers must have a written policy on how they handle such changes.
• Multiple employments: If the member has more than one firefighter job, each job is treated separately. A distinct contribution rate is set for each employment based on the actual pay for that specific role.
• Assumed Pensionable Pay (APP): In specific circumstances, such as during sickness, injury, or relevant child-related leave (e.g., ordinary maternity/adoption leave), the pension is based on your “assumed pensionable pay” (APP) to ensure the pension build-up is not negatively affected by a drop in actual pay. Contributions are still deducted from any actual pay received during these periods, but the pension built up is based on the higher APP figure.
• Non-pensionable pay exclusions: Certain payments are excluded from pensionable pay, such as compensation awards.

This approach ensures that contributions reflect real-time earnings, including fluctuations due to overtime, pensionable allowances, or variable hours—particularly relevant for retained firefighters.

Question 3: What is your preferred futureproofing option to avoid future misalignment?

• Option 1: Manually uplifting thresholds in line with the pay awards.
• Option 2: Automatically increase thresholds in line with the consumer price index (CPI)

There were 23 responses to question 3, of which 48% favoured Option 1, 26% favoured Option 2 and 23% did not support either.

Option 1 was favoured for its flexibility and its ability to reflect actual changes in earnings more accurately than a fixed index. Respondents highlighted that it allows for closer alignment with sector-specific pay dynamics and would reduce the risk of misalignment that can occur with inflation-based adjustments such as the Consumer Price Index (CPI).  There were some concerns about how this would be administered, particularly if there were late awards, or where awards are retrospective, leading to changes partway through the year.

Some respondents were concerned about complexity of administering a manual uplift, especially for senior staff, where pay awards are not nationally agreed.

For Option 2, it was noted that pay awards are based on CPI from the previous year. It was proposed that if contribution bandings were uplifted using a different index, there would be a disparity between contributions and pay. While CPI was seen as a more predictable and administratively straightforward mechanism, concerns were raised about its potential to drift from real pay trends.

One response requested more clarity on when updated thresholds would need to come into effect, and whether this would be at the beginning of the scheme year, the effective date of the pay award, or within a set period after the agreement of the pay award.

There was broad support for uplifting contribution thresholds to maintain a relationship between pay structure and pension contribution thresholds.

A number of respondents proposed alternative approaches. There were 7 responses (30%) which suggested linking thresholds to Average Weekly Earnings (AWE), which is already used for CARE revaluation. These respondents argued that AWE would provide a more consistent and relevant benchmark for the fire sector.

However, there were some suggestions that as AWE is generally higher than CPI, this would not offer a useful method of futureproofing, as it would quickly lead to a misalignment between pay scales and contribution rates.

Government Response

The government acknowledges the strong interest among respondents in ensuring that the member contribution structure remains responsive to changes over time. Many respondents supported manual uplifts aligned with firefighters’ pay awards, others proposed automatic mechanisms such as linking thresholds to CPI.

After careful consideration of the consultation responses, the government has decided to provide an indexing mechanism that is aligned with CPI to be implemented from April 2027. Manually uplifting would need timely confirmation of pay settlements, system updates, and clear communication to the members. Implementing CPI uplifts will provide protection to members, is less administratively complex and aligns with other public sector pension schemes – the Civil Service, Teachers,’ and Local Government Pension Schemes. Implementing CPI from 2027 will provide amply time for administrators to update their systems.

Indexation will apply annually on 1 April (from 2027), and the CPI rate used will be the September rate from the previous year. The government will keep the implementation of CPI indexation under review to ensure that long-term stability is provided for the scheme.

We recognise that CPI may differ from firefighters’ pay awards; however, we believe it is essential to introduce indexation to protect members and ensure, as far as possible, that contribution rates remain accurate and fair. Linking thresholds to CPI provides a consistent and transparent approach, reduces administrative complexity, and helps maintain stability within the scheme over time.

Question 4: Do you believe that your preferred contribution structure option, which you indicated in Question 1, is administratively sustainable?

We received 22 responses. Of those who supported Option 1, 100% agreed, and of those who supported Option 2, 100% agreed and of those supported Option 3, 100% were unsure.

Supporters of Option 1 stated that it was straightforward and sustainable for administrators and would avoid any additional work created by the addition of a new contribution tier.

Similarly, those respondents supporting Option 2 noted that existing payroll systems were already able to manage tiered pension contribution rates and could be easily configured to include additional tiers.

Many responses explicitly stated that Option 3 would not be possible within current payroll software. Those who supported Option 3 stated that practicality and cost needed to be considered, and that any changes to contribution rates would create an administrative burden for FRAs.

Responses stated that there needed to be the ability to review the contribution structure if it was no longer sustainable on administration or fairness grounds.

Government Response

The government is reassured by the strong consensus that the proposed updates to the tiered contribution structure is considered deliverable by most employers and administrators, with many noting that their payroll systems are already configured to support tiered contributions and could be configured to include additional tiers.

The proposed policy aligns well with the majority of respondents who indicated that the current tiered structure, with updated thresholds, is administratively sustainable. This approach leverages the existing system, which is already familiar to FRAs and their payroll providers, ensuring a smooth transition and minimising administrative burdens.

Protecting lower-paid members and ensuring compliance with the Public Sector Equality Duty are key policy objectives that are addressed by maintaining affordability within the tiered structure and conducting an equality assessment.

Overall, this proposal strikes a balance between minimising administrative complexity, ensuring financial sustainability, and maintaining fairness and affordability for all members.

Question 5: Are there any other proposals for achieving the target yield through contribution structures that you would like to be considered which have not been considered or proposed in this consultation?

Ten respondents had additional proposals that they wanted to put forward, 42% of the total number of respondents. The following is a summary of the alternatives proposed:

• A flat rate for all members, replacing the tiered structure with a single flat contribution rate for all members.
• The same increase in contributions for all roles.
• Lower contribution rates for low paid staff, and/or lower contributions for early career firefighters. In general, these were intended to reduce opt-out rates. There were different suggestions for how this could work, including reducing the number of contribution bands to three, with the majority of staff paying the same rate.
• Introducing a 50/50 model, similar to that used in the LGPS allowing members to pay half the standard contribution rate in exchange for half the pension accrual. It was suggested that this would reduce opt-outs.
• Broader structural reforms to reduce financial pressures on those in senior positions and on higher pay, to encourage progression.
• A review of the target yield, and whether the current target yield remains appropriate in light of broader economic pressures and the cost-of-living crisis, suggesting that the assumptions underpinning the yield should be revisited.
• Rounding of contribution rates to 1 decimal place for simplicity.

Additionally, one respondent asked for more regulations and guidance on how thresholds should be calculated for retained or on-call firefighters if contribution rates were based on actual pensionable pay, as pay can vary month to month. They suggested that the assessment should be done on a three-month rolling basis. This response was more relevant to Question 3.

Government response to question 5:

The government is grateful for these contributions and suggestions and will retain them for consideration in any future, broader review of the scheme.

For the purposes of this consultation, the government has focused only on proposals that fall within the scope set out in the consultation document, which is on adjustments to member contribution rates, thresholds, and tiering within the existing framework of the Firefighter’s Pension Scheme.

Suggestions of a flat rate for all members would simplify administration and ensure uniformity, but it would represent a fundamental change to the tiered approach agreed as part of the 2015 scheme design. Graduated contributions based on career stage could support participation and affordability but would introduce a contribution model based on service length rather than pensionable pay, which would be a significant departure from the principles of the current scheme.

As part of the consideration of this response, the government noted suggestions around refinements to the tiered model. Other suggestions were outside the scope of the consultation. In response to the suggestion that the target yield should be revisited, it should be noted that the target yield is set in accordance with the scheme’s valuation and the broader public service pension framework.

Question 6: Do you anticipate any equality issues arising from the implementation of these proposals?

There were 21 responses, of which 38% did anticipate equality issues, 24% did not anticipate equality issues and 38% were unsure.

Some respondents noted that steep increases in contribution rates between tiers could act as a disincentive to promotion, particularly for those on the cusp of a higher tier. This could disproportionately affect members from underrepresented groups who may already face barriers to progression.

Some answers related directly back to other elements of the consultation. For example, there were references to calculating contributions based on WTE, as opposed to actual pensionable pay, which was the subject of Question 2. Some respondents considered that maintaining a WTE structure would be discriminatory to part-time staff, and that moving to using actual pensionable pay would not create any equality issues.

Some responses related to the implementation of changes to contribution bands. It was suggested that if not implemented correctly, a part time member could pay a lower rate than a full-time member, and then if that member moved to full time service, would remain on a lower rate and pay fewer contributions than a full-time colleague on the same pay. There were also concerns about how temporary promotions would be factored into calculations. It was suggested that this could be resolved if a review could be factored in when substantial changes in employment take place.

For those who selected ‘don’t know,’ for some this was because there was not a published equality impact assessment alongside the consultation response.

Across all responses, concern was expressed for the treatment of part-time staff and ensuring that the solutions adopted were fair for them.

Government Response

The government is committed to ensuring that any changes to the 2015 Scheme are fully compliant with the Public Sector Equality Duty (PSED) under the Equality Act 2010. This includes having due regard to the need to:

• Eliminate unlawful discrimination, harassment, and victimisation;
• Advance equality of opportunity between people who share a protected characteristic and those who do not;
• Foster good relations between people who share a protected characteristic and those who do not.

In response to the concerns raised:

• The government has decided to base contribution thresholds on actual pensionable pay, rather than WTE pay. This approach better reflects the earnings of part-time and retained firefighters and helps to mitigate the risk of indirect discrimination, particularly on the grounds of sex & age.

• The revised tier structure under Option 2 (Add an additional tier and modify the gap between tiers) has been designed to minimise cliff edges between bands, thereby reducing the risk of promotion disincentives. The government recognises the importance of ensuring that contribution structures do not act as a barrier to progression, especially for underrepresented groups.

• An Equality Impact Assessment (EIA) has been conducted and published alongside this response. The EIA considers the potential impacts of the proposed changes across all protected characteristics, including age, sex, race, disability, and working patterns. It will continue to be reviewed and updated, as necessary.

The government will also monitor the implementation of the revised contribution structure to ensure that it does not result in unintended or disproportionate impacts on any group. This includes working with the SAB, LGA and employers to gather feedback and assess outcomes over time.

In conclusion, the government is satisfied that the proposed changes are consistent with its obligations under the Equality Act 2010 and will continue to ensure that equality considerations remain central to the design and delivery of the scheme.

Impact Assessment and Equalities

Equalities Impact Assessment

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.

This involves having due regard to the need to:

• remove or minimise disadvantages suffered by people due to their protected characteristics; and
• Take steps to meet the needs of people from protected groups where these are different from the needs of other people.

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.

Stakeholder engagement and informal consultation have supported the government in identifying any potential risk of adverse impacts in relation to the protected characteristics. Such stakeholder engagement includes engagement with fire sector employer and employee representatives, other government departments, and devolved administrations. The government has produced an Equality Impact Assessment that is published alongside this response.

The department has considered the impact of the changes in the context of the PSED in the Equality Impact Assessment. The PSED is an ongoing duty, and we will continue to consider and amend this assessment. More information on the PSED can be found here: Public Sector Equality Duty: guidance for public authorities - GOV.UK

Conclusion and next steps

The government is grateful to all those who responded to this consultation. The views and evidence submitted have been carefully considered and have informed the government’s final policy position.

The consultation confirmed broad support for retaining a tiered contribution structure, with a clear preference for introducing an additional tier and modifying the gap between tiers. This approach was seen as more equitable, administratively sustainable, and better aligned with the structure of other public service pension schemes. Respondents also highlighted the importance of protecting lower-paid members, supporting scheme participation, and avoiding disincentives to promotion.

In determining how contribution thresholds should be assessed, the government acknowledges the support for both Whole-Time Equivalent (WTE) pay and actual pensionable pay. While WTE was favoured for its simplicity, there was still considerable support for actual pensionable pay, and the government has concluded that using actual pensionable pay provides a fairer and more accurate reflection of members’ earnings - particularly for part-time and retained firefighters - and is therefore the most appropriate basis for determining contribution rates.

The government also recognises the importance of future proofing the contribution rates on an annual basis to keep pace with any pay increase in the future. To ease admin burden and to align with other public sector pension schemes we deem using the Consumer Price Index (CPI) the best way to provide protection.

A number of alternative proposals, including a 50/50 option and career-stage-based contributions, were submitted. While these fall outside the scope of this consultation, they have been noted for future consideration as part of any broader review of the scheme.

Implementation

The revised contribution structure will be implemented through amendments to the 2015 Scheme (England) Regulations 2014. These changes will take effect from 1 April 2026, in line with the start of the new scheme year, with the CPI uplift effective from 1 April 2027.

The government remains committed to ensuring that the 2015 Scheme continues to be fair, sustainable, and valued by its members. The contribution structure will be kept under review to ensure it remains appropriate and responsive to the needs of the workforce and the requirements of the scheme.

Appendix A: Examples

This appendix examines the impact of several different member contribution structures on three example members, selected based on.

The example member profiles considered are:

Member	Role	Pay basis	WTE / reference pay	Actual pay	Assumed marginal rate of income tax
1	Competent Firefighter	Wholetime Equivalent	£37,675	£37,675	20%
2	Watch Manager Competent B	Retained	£46,707	£20,000	20%
3	Area Manager Competent B	Wholetime, with 20% flexible duty allowance	£86,465	£86,465	40%

Pay impacts are shown based on 2024/25 income tax rates and thresholds at the time of writing (November 2024).

Future pay increases are assumed to be in line with the 2020 valuation, i.e.:

• 1 July 2025: 1.6%
• 1 July 2026: 1.9%

All examples assume that the pay thresholds do not increase over 1 October 2025 to 31 March 2027. This means that selecting different future pay increase assumptions may affect the resulting structures for each example.

Note, all amounts shown are rounded to the nearest £1.

For reference, the existing structure is as below:

Tier	WTE / reference pay	Rate
1	£0 to £27,818	11.0%
2	£27,819 to £51,515	12.9%
3	£51,516 to £142,500	13.5%
4	£142,501 and above	14.5%

This structure is not projected to meet the target yield. This example is only included as a basis for comparison against the following examples.

The contributions paid by each example member under the current structure are:

Member	Pay used to determine rate	Rate payable	Pay contributions are paid on	Contributions paid before tax relief: annual	Contributions paid before tax relief: monthly	Contributions paid after tax relief: annual	Contributions paid after tax relief: monthly
1	£37,675	12.9%	£37,675	£4,860	£405	£3,888	£324
2	£46,707	12.9%	£20,000	£2,580	£215	£2,064	£172
3	£86,465	13.5%	£86,465	£11,673	£973	£7,004	£584

Example 1: current structure with rates determined by actual pay, solved to meet the target yield

This example takes the existing structure but uses individuals’ actual pay, rather than WTE pay, to determine the rate payable. The steps between each rate in the current structure is maintained. This structure is as below:

Tier	Actual pay	Rate
1	£0 to £27,818	11.38%
2	£27,819 to £51,515	13.28%
3	£51,516 to £142,500	13.88%
4	£142,501 and above	14.88%

The proportion of pay falling into each tier under this structure is as below:

Tier	Proportion of pay in each tier over 1 October 2025 to 31 March 2027
1	11%
2	69%
3	19%
4	1%

The contributions paid by each example member under this structure are:

Member	Pay used to determine rate	Rate payable	Contributions paid before tax relief: annual	Contributions paid before tax relief: monthly	Contributions paid after tax relief: annual	Contributions paid after tax relief: monthly
1	£37,675	13.28%	£5,003	£417	£4,003	£334
2	£20,000	11.38%	£2,276	£190	£1,821	£152
3	£86,465	13.88%	£12,001	£1,000	£7,201	£600

The following table sets out the change in contributions relative to the existing structure for each example member:

Member	Change in contributions paid before tax relief: annual	Change in contributions paid before tax relief: monthly	Change in contributions paid after tax relief: annual	Change in contributions paid after tax relief: monthly
1	+ £143	+ £12	+ £115	+ £10
2	- £304	- £25	- £243	- £20
3	+ £329	+ £27	+ £197	+ £16

Example 2: current structure with pay thresholds increased with pay awards since 1 April 2018, solved to meet the target yield

This example takes the existing structure, last updated on 1 April 2018, and increases the pay thresholds in line with pay awards from July 2018 to July 2024 inclusive. This structure is as below:

Tier	WTE pay	Rate
1	£0 to £35,010	11.36%
2	£35,011 to £64,834	13.26%
3	£64,835 to £184,778	13.86%
4	£184,779 and above	14.86%

The proportion of pay falling into each tier under this structure is as below:

Tier	Proportion of pay in each tier over 1 October 2025 to 31 March 2027
1	7%
2	83%
3	10%
4	<1%

The contributions paid by each example member under this structure are:

Member	Pay used to determine rate	Rate payable	Contributions paid before tax relief: annual	Contributions paid before tax relief: monthly	Contributions paid after tax relief: annual	Contributions paid after tax relief: annual
1	£37,675	13.26%	£4,996	£416	£3,997	£333
2	£46,707	13.26%	£2,652	£221	£2,122	£177
3	£86,465	13.86%	£11,984	£999	£7,190	£599

The following table sets out the change in contributions relative to the existing structure for each example member:

Member	Change in contributions paid before tax relief: annual	Change in contributions paid before tax relief: monthly	Change in contributions paid after tax relief: annual	Change in contributions paid after tax relief: monthly
1	+ £136	+ £11	+ £109	+ £9
2	+ £72	+ £6	+ £58	+ £5
3	+ £311	+ £26	+ £187	+ £16

Example 3: illustrative 5-tier structure based on actual pay solved to meet the target yield

This example takes the existing structure, last updated on 1 April 2018, and increases the pay thresholds in line with pay awards from July 2018 to July 2024 inclusive. The resulting tier 2 is then divided into two with approximately equal amounts of pay in each of the new tiers 2 and 3 to create a 5-tier example. Actual pay is used to determine the rate members pay. This structure is as below:

Tier	Actual pay	Rate
1	£0 to £35,010	11.09%
2	£35,011 to £43,999	12.59%
3	£44,000 to £64,834	14.09%
4	£64,835 to £184,778	15.59%
5	£184,779 and above	17.09%

The proportion of pay falling into each tier under this structure is as below:

Tier	Proportion of pay in each tier over 1 October 2025 to 31 March 2027
1	17%
2	37%
3	36%
4	10%
5	<1%

The contributions paid by each example member under this structure are:

Member	Pay used to determine rate	Rate payable	Contributions paid before tax relief: annual	Contributions paid before tax relief: monthly	Contributions paid after tax relief: annual	Contributions paid after tax relief: monthly
1	£37,675	12.59%	£4,743	£395	£3,795	£316
2	£20,000	11.09%	£2,218	£185	£1,774	£148
3	£86,465	15.59%	£13,480	£1,123	£8,088	£674

The following table sets out the change in contributions relative to the existing structure for each example member:

Member	Change in contributions paid before tax relief: annual	Change in contributions paid before tax relief: monthly	Change in contributions paid after tax relief: annual	Change in contributions paid after tax relief: monthly
1	- £117	- £10	- £93	- £8
2	- £362	- £30	- £290	- £24
3	+ £1,807	+ £151	+ £1,084	+ £90

Example 4: marginal structure with pay tier thresholds set in line with those applying from 1 April 2018, increased with pay awards to 1 July 2024

This structure works differently to the other example structures. It is designed to operate similarly to the income tax structure, where a member will pay the lowest rate on the pay that falls within tier 1, followed by paying the tier 2 rate on any pay above the tier 1 threshold and below the tier 2 threshold, and so on. This effectively results in each member having an individualised effective contribution rate. Implicitly, this structure uses actual pay to determine the contribution rate payable.

The pay thresholds are the same as in Example 2, i.e. based on the pay thresholds for the current tiers but increased with pay awards since 1 April 2018 (when they were last updated). The steps between each rate have been set at 2.5% for illustrative purposes only.

This structure is set out below:

Tier	Actual pay	Rate
1	£0 to £35,010	12.63%
2	£35,011 to £64,834	15.13%
3	£64,835 to £184,778	17.63%
4	£184,779 and above	20.13%

Under this example marginal structure, a member earning £190,000 would not pay 20.13% on their whole pay, only on their pay above £184,778.

The proportion of pay falling into each tier under this structure is as below:

Tier	Proportion of pay in each tier over 1 October 2025 to 31 March 2027
1	79%
2	19%
3	2%
4	<1%

The contributions paid by each example member under this structure are:

Member	Pay used to determine rate	Effective contribution rate	Contributions paid before tax relief: annual	Contributions paid before tax relief: monthly	Contributions paid after tax relief: annual	Contributions paid after tax relief: monthly
1	£37,675	12.81%	£4,825	£402	£3,860	£322
2	£20,000	12.63%	£2,526	£211	£2,021	£168
3	£86,465	14.74%	£12,748	£1,062	£7,649	£637

The following table sets out the change in contributions relative to the existing structure for each example member:

Member	Change in contributions paid before tax relief: annual	Change in contributions paid before tax relief: monthly	Change in contributions paid after tax relief: annual	Change in contributions paid after tax relief: monthly
1	- £35	- £3	- £28	- £2
2	- £54	- £5	- £43	- £4
3	+ £1,075	+ £90	+ £645	+ £54

If a marginal structure were to be introduced partway through 2025/26, the effective contribution rate would be determined based on the member’s earnings over the full scheme year.

Appendix B: Projected Yield Methodology

The methodology used by GAD to calculate the expected yield over 1 October 2025 to 31 March 2027 is briefly summarised below.

1. The starting point is membership pay data as of 31 March 2024.
2. For each member, pensionable pay is then calculated over each scheme year, 2025/26 (partial year) and 2026/27, by applying the known pay award from July 2024 followed by assumed pay increases based on 2020 valuation assumptions but assumed to apply in July each year. Different assumptions for future pay increases would have an impact on the projected yield for the examples shown.
3. For each year, an individual’s pensionable pay (whole-time equivalent unless otherwise specified) is assessed against the member contribution structure to determine their applicable contribution rate.
4. The applicable rate is applied to each member’s projected actual pensionable pay to estimate the monetary value of contributions that would be payable in each year.
5. Total member contributions are summed and then divided by the total projected actual pensionable pay to calculate the member contribution yield as a proportion of total pensionable pay.
6. The average projected yield over 1 October 2025 to 31 March 2027 is then calculated – this is 13.0% pa based on current contribution structure, compared to the target yield of 13.2% pa.

GAD does not apply any promotional pay increases as it is assumed that these will be offset by members leaving and being replaced by new members entering the population lower down on the salary scale. This effectively assumes a stable workforce in terms of the number of members at each pay point.