Consultation outcome

Chapter 2: Encouraging consolidation

Updated 21 June 2021

Background

1. Chapter 3^{[footnote 5]} of the February 2019 consultation made the case for a more consolidated defined contribution (DC) pensions market. We believe consolidation is the most effective way to ensure that all savers are receiving the best value from well governed schemes that can achieve economies of scale. Consolidation will also deliver greater opportunities for members to access a more diverse range of investment products and investment strategies to the benefit of both the pension saver and the broader UK economy.

2. The consultation considered measures to accelerate the existing rate of consolidation and sought feedback on those suggestions. This chapter summarises the responses we received and sets out our proposal to accelerate consolidation and improve both governance and access to a wider range of asset classes, including illiquids.

Current position

3. The market is continuing to consolidate, with a 12% fall in scheme numbers^{[footnote 6]} in the past year. Employer switching is expected to continue at a rate of between 5 and 10% each year.^{[footnote 7]} However, schemes at the smaller end of the market are consolidating more slowly, and it is these schemes that are the focus of our proposals.

4. Of around 3000 DC schemes^{[footnote 8]} on the Pensions Regulator’s (TPR) register, approximately 2150 have 100 members or less. Of these, approximately 850 have between 12 and 100 members and 1300 have less than 12 members.

5. In 2019, around 60% of schemes with less than 100 members did not meet any of the 5 Key Governance Requirements (KGRs) set by TPR.^{[footnote 9]} Most smaller schemes are also paying higher charges than larger schemes, with average charges in smaller schemes nearly double that of the largest schemes.^{[footnote 10]} Members of some of these smaller schemes are therefore likely to achieve better value in a larger scheme, and our February 2019 consultation explored ways in which this might most effectively be achieved within the market.

February 2019 policy proposals

6. In the Investment Innovation and Future Consolidation consultation we set out proposals intended to encourage and support those trustees who had not previously considered consolidation to now explore it as a course of action.

7. We proposed extending the scope of the current ‘value for members’ assessment in the Chair’s Statement for smaller DC schemes. This revised and more holistic assessment would ask trustees of those smaller schemes to declare whether their scheme was achieving sufficient value for money for savers’ retirement income, or whether it might be in scheme members’ interests to move to a larger scheme or an authorised master trust.

8. We sought opinion on the size of schemes that should come into scope for this new assessment, how frequently it should be carried out, and the factors that should be considered as part of that assessment. We also asked for views on the appropriate reporting vehicle.

Overview of stakeholder responses

9. We received a total of 56 responses from a mix of organisations across the industry. A full list can be found at Annex A.

10. The proposals were broadly well received by the majority of respondents; only 8 were sceptical or cautious and 5 opposed. The majority of respondents agreed that an extended value for members assessment in the chair’s statement would be a good way to get trustees to consider whether scheme members’ interests would be better served by consolidating. There were caveats to their support, including that the requirements should not take effect immediately.

11. Respondents agreed that benefits of consolidation for scheme members included being part of a better governed scheme and having access to a more diverse range of investment opportunities, and in some cases to more competitive charges.

Stakeholder responses to detailed questions

12. Some stakeholders felt that encouraging consolidation should wait until the master trust authorisation process had completed so that smaller schemes would have a well-established market to choose from.

13. Of those in support of the proposal, a few felt that consolidation should be for the purpose of increasing value for members only, and perceived the argument for access to illiquid investments as being less strong.

14. The most common reason given by those who were less enthusiastic about focusing on consolidation was that not all small schemes are badly run and therefore consolidation should not be an automatic requirement. For those that are badly run, effort should instead be focused on improving their standards of governance.

15. One respondent did not believe that it was within the remit of trustees to consider whether scheme members would be better off transferring elsewhere. It would be up to the employer to consider this option.

16. A couple of respondents raised concerns about the cost of wind up. A small number of others felt consideration of consolidation would not be an appropriate use of the trustee board’s time and governance efforts.

Government response

17. We were encouraged by the overall level of support for our proposals to encourage consolidation. We agree with the majority view on timing in relation to the master trust authorisation process and believe, now that process is complete and the supervision regime is a year into operation, that it is the right time to consult further on these proposals.

18. We acknowledge that not all small schemes are badly run and that many trustees of smaller schemes work diligently, often on a voluntary basis, to protect the interests of scheme members. There are also particular classes of smaller bespoke schemes that are highly regarded and offer valuable benefits. Schemes that are delivering value to their members will be able to demonstrate this under the proposed new assessment.

19. We are also aware that many smaller schemes struggle to achieve economies of scale and to access the services and investment strategies offered to the larger end of the market. Data from TPR^{[footnote 11]} on the degree to which schemes are meeting Key Governance Requirements also shows that a majority of smaller schemes are struggling to govern effectively. All savers should enjoy the benefits of well-run schemes that can deliver high standards of governance, efficient and effective charging structures and diverse investment strategies.

20. We do not agree that it is not within the remit of trustees to determine whether scheme members’ interests would be better served by winding up and consolidating. Trustees would, in consultation with the employer, be expected to make a decision to consolidate where their own assessment shows that their scheme is unable to effectively deliver value for money. TPR also has the power to wind up a pension scheme in certain circumstances, including if to do so would be in the interests of the generality of members.

21. We therefore propose that where smaller schemes do not demonstrate value for members under the new assessment, trustees should take immediate steps to wind up the scheme and consolidate members into a larger scheme, unless in exceptional circumstances they can improve both rapidly and cost effectively. We set out which smaller schemes this proposal would apply to in the section on Scope, below.

22. We accept that some poorly performing schemes that fail to meet the standards under the new assessment may be able to improve sufficiently without needing to consolidate. We would expect, however, that such schemes would make these improvements before their assessment falls due.

23. Trustees of schemes that do fail to demonstrate value for money under the new assessment should weigh up the time, skills, capacity and costs of making sufficient improvements. They should be confident that they can raise standards to meet and continue to meet the ongoing demands of managing savers’ money over the long term. We believe that wind up and consolidation into a larger, better value scheme is still likely to be the best option for members.

24. Only in exceptional instances where trustees have solid reason to believe that they can make all required improvements cost-effectively and efficiently, despite having failed to demonstrate this at assessment, would we expect trustees to seek to improve rather than to initiate wind up. Schemes that attempt to improve are expected to achieve these improvements within a reasonable period of time, and if they do not, they should take action to wind up and consolidate without further delay to prevent continued detriment to scheme members.

25. It is not acceptable for savers to be enrolled in arrangements that do not deliver value in terms of costs, investment returns or secure and resilient governance. Government would expect trustees acting in the best interests of their members to take appropriate action to wind up and consolidate without TPR needing to exercise its powers.

26. TPR has the power to order schemes to wind up if it is in the best interests of the generality of scheme members to do so. TPR also has the power in certain circumstances to remove or appoint trustees, and to order trustees or third parties that are causing breaches of pensions legislation to make specific improvements to be made within a certain period of time.

27. We do not propose that the costs of winding up the scheme would be a factor to consider when completing the value for members assessment as it is not a metric that impacts the value achieved by the scheme while it is in operation. These costs do of course need to be taken into account once trustees are considering consolidation. Trustees will also need to consider the role of the employer in winding up and selecting a new scheme, as well as the costs associated with the wind up process, including any exit charges, and whether there are any existing guarantees that might be lost.

Summary

It is proposed that these regulations will come into force on 5 October 2021.

If the trustees of a smaller scheme consider that the scheme is not delivering good overall value following its value for members assessment, Government expects trustees to wind up the scheme and consolidate.

In circumstances where trustees are realistically confident that required improvements can be made, and/or where the wind up and exit costs may exceed the costs of making such improvements, and/or where there are valuable guarantees that would be lost on consolidation, the scheme may seek to improve. If the trustees fail in this attempt to improve they will be expected to wind up the scheme and consolidate the members into a scheme that offers better value.

Trustees must report their proposed approach to TPR. TPR has the power to issue an order to wind up the scheme, to remove trustees in certain circumstances, or to appoint new trustees to properly manage the scheme’s assets.

Scope

28. In the consultation we suggested that these proposals should apply to schemes with fewer than 1000 members, or with less than £10 million in money purchase benefit assets. The majority who responded to this question felt that the total amount of assets should be used as a threshold rather than number of members.

29. The majority of respondents agreed with our suggested £10 million threshold, although there were some suggestions that the threshold should be higher, to include poor value larger schemes, or lower to help ensure well run smaller schemes could continue to operate. One respondent felt that that there should be no size requirement and that all schemes that are less well governed should improve or consolidate.

30. Some respondents felt that schemes established within the last three years should be allowed to grow and should therefore be exempt from these requirements.

Government response

31. We note the majority agreement with our suggestion of a threshold for schemes with assets of less than £10 million. We also note that the picture for schemes with assets above £10 million is more mixed, but that schemes of a slightly larger scale do still experience difficulties with governance, operational resilience, or with accessing economies of scale and a diverse mix of assets. We are therefore consulting on regulations that set a threshold of £100 million to complete the new and more holistic value for members assessment, having regard to new statutory guidance. A draft of this guidance is attached at Annex E.

32. We believe that setting the threshold at this level will encourage further economies of scale and lead to more diverse investments, including illiquid assets.

33. We acknowledge that new schemes take time to establish and grow. We agree that schemes that have been in operation for less than three years at the time that the assessment falls due should be exempt from the new requirements.

34. Achieving value for members is important for all occupational pension schemes, regardless of their size or duration. All schemes that fall outside the scope of the draft regulations must still assess value for members in relation to their charges and transaction costs under the existing regulations as explained in TPR’s Code and Guidance.^{[footnote 12] [footnote 13]} They may also choose to have regard to the new assessment, if they wish to do so.

Summary

Scope:

We propose that the new value for members assessment applies for schemes with less than £100 million in total assets that have been operating for at least 3 years at the end of the previous scheme year from when their chair’s statement falls due.

Metrics to assess value for members

35. We suggested that charges, investment performance and governance and administration should be included when assessing value for members, and we sought views on whether there should be a reference scheme for comparison.

36. The majority of respondents thought that all of these suggested factors should be considered in the value for members assessment. Some respondents stated that costs should not be considered on their own but assessed in relation to the returns obtained - a small scheme with high costs could still produce high returns and therefore deliver value for its members.

37. One respondent indicated that exit penalties and existing guarantees should also be considered, while a small number of respondents expressed the view that factors such as the level of member engagement and the quality and frequency of communication with scheme members should also be considered because this impacts members’ decumulation decisions.

38. Other factors raised included the level of employer support, fund switch capability, fund range and flexibility at retirement, and trustee knowledge and understanding. Two respondents were concerned that any form of prescriptive reporting would place additional resource burdens on schemes, and one argued that administration and governance factors are too subjective to compare easily.

39. There was little support for the idea of having a single reference scheme as a comparator. One respondent commented that this would have to be reviewed or updated regularly and another that only an automatic enrolment master trust with a “one size fits all” proposition would be appropriate.

40. Some respondents suggested that a couple of market based reference schemes could be used, and there was a preference for comparing against what is available in the market rather than against a model scheme.

41. Many respondents raised the need for additional guidance for trustees in completing the assessment.

Government response

42. We agree that while costs and charges have a significant impact on member outcomes they are best understood in the broader context of what the scheme delivers. The net returns received is a crucial factor in measuring value for members. Therefore, alongside information about costs and charges, we propose that trustees also consider the level of net investment returns as part of the assessment, for various age cohorts where applicable.

43. We are consulting on regulations that will require all relevant ^{[footnote 14]} schemes, regardless of size, to publish net returns for their default and self-selected funds. This will not only assist with completing the Value for Members assessment but will also provide greater transparency to members. Draft regulations are at Annex C and draft revisions to the statutory guidance on the reporting of costs and charges is at Annex G.

Summary

We propose that in order to provide greater transparency to members all relevant schemes, regardless of size, must publish net returns for their default and self-selected funds in the annual chair’s statement. We welcome your views on how this information might be most usefully calculated and reported on in question Q1 below.

44. We agree that a single reference or model scheme should not be used. We propose that smaller schemes should compare themselves to at least three other larger schemes in the market. Of the three schemes, trustees should have reason to believe that at least one of them would accept the smaller scheme should it decide to wind up and consolidate.

45. We propose producing statutory guidance in response to the view that trustees would benefit from additional support to in carrying out their value for member assessment. A draft of this guidance is available for review at Annex E.

46. The quality of scheme governance and administration is a significant part of a schemes’ overall value proposition. We propose that our statutory guidance include a breakdown of what we expect trustees should consider when looking at the quality of the administration and governance of a scheme. These criteria are:

• quality of record keeping
• promptness and accuracy of core financial transactions
• quality of communication with members
• appropriateness of the default investment strategy
• the quality of investment governance

47. We also propose that trustees consider their skills, knowledge and understanding, and the effectiveness of their conflict of interest management. Smaller schemes will not be expected to use any external comparator for this element of their value for money assessment. Instead, we propose that they assess the value offered by their administration and governance on an absolute basis. In conducting this assessment, trustees should have regard to TPR’s education, guidance and Codes of Practice on this subject as set out in its 21st Century Trusteeship initiative^{[footnote 15]}, and to the additional statutory guidance we propose to publish.

48. Where an employer subsidises the running costs of the scheme, as is often the case with administration charges, we suggest that this will need to be taken into consideration when assessing value.

49. We agree that the benefits of existing guarantees should also be considered when making the overall holistic assessment of whether a small scheme provides value for members.

50. We have not proposed scheme member engagement as a specific measure of the value offered by a scheme. We have proposed member communication, as it is important that members have clear, accurate and timely information made available when they need to make decisions about their savings. We have also not proposed fund switch capability, fund range or flexibility at retirement as being main factors to consider in the assessment.

51. We do not envisage that consideration and reporting of the above factors is likely to significantly impact on trustee time, resources or scheme costs. These are matters that should be considered by trustees throughout the scheme year and should therefore be easily accessible. If trustees struggle to consider and report on such elements, this in itself should prompt them to consider the extent to which they feel they are able to effectively govern the scheme while still delivering value.

Summary

The proposed factors to be assessed are:

• costs/charges
• net investment returns

• measures of administration and governance which include:

  • promptness and accuracy of financial transactions
  • appropriateness of default investment strategy
  • quality of investment governance
  • quality of record keeping
  • quality of communication with members
  • level of trustee knowledge, understanding and skills to run the scheme effectively
  • effectiveness of management of conflict of interest

Costs, charges and net returns would be assessed relative to those of at least 3 other schemes while factors of administration and governance would be assessed absolutely within the scheme.

52. We also sought views on an appropriate reporting vehicle and suggested the reporting requirement be added to the value for members assessment which forms part of the DC chair’s statement.

All respondents felt that the DC chair’s statement was a suitable vehicle for reporting on the more detailed value for members assessment. One indicated that it would be suitable provided that it did not make the chair’s statement long and burdensome.

53. One respondent went further to say that the assessment should be evidenced while another said there needed to be mandatory reporting to TPR and an action plan submitted where appropriate.

Government response

54. The proposals are an extension of the existing mandatory requirements to assess and report on value for members in relation to charges and transaction costs in the chair’s statement. The government would expect trustees to fully explain in the statement what they have done to demonstrate the value they deliver and how they have reached their conclusion on the outcome of the assessment.

55. We propose that schemes will be required to report the overall outcome of the assessment to TPR via the scheme return and indicate how they will proceed, should the scheme not provide good value for members. TPR will use its regulatory powers where necessary, including its power to wind up a pension scheme where to do so is in the interest of the generality of its members.

Summary

We propose that schemes in scope will complete the prescribed value for members assessment annually and report on it as part of their DC chair’s statement. Trustees must also report to TPR, in their next annual scheme return, the outcome of the assessment and what intended action they will take, or have already started to take, in the event that the scheme does not present good value for members.

56. We asked for views on the appropriate frequency of the value for members assessment, suggesting at least every three years and after any significant change in size or demographic profile.

57. Of those who responded to this question, a majority agreed that a triennial basis was appropriate. A few respondents suggested reporting could be made more frequent during periods of change within the scheme. Others suggested triennial reporting was not frequent enough and that the assessment should be done annually or on alternate years.

58. One respondent thought that every 5 years was more appropriate, and another that the date of reviews should be staggered to ensure schemes have access to quality advice.

Government response

59. We believe it would be appropriate for the assessment to be carried out annually, as part of the annual chair’s statement. We do not believe this to be disproportionate as the factors to be assessed are those that trustees should be reviewing throughout the year.

60. We understand concerns about access to quality advice but are not convinced that it is necessary to stagger reporting. We do not propose to compel schemes to increase the frequency of assessment following changes within the scheme, such as to the demographic profile.

Summary

We propose that the new value for members assessment will be conducted annually by the schemes in scope.

61. Finally, we asked what other indicators should be looked at to encourage schemes to consider consolidation. We suggested that trustee knowledge and understanding, open or closed status and member demographics may be appropriate.

62. For those who responded on trustee knowledge and understanding, while the majority considered it to be an important factor for any scheme, the responses as to whether it should be included as a measure were mixed. A narrow majority believed that it should be included. Comments included the difficulty of measurement and enforcement, and that assessment was very subjective.

63. One respondent who supported it as a measure commented that lack of trustee knowledge of investment may be limiting the quality of investment and decumulation choices made by members and that this was important to capture.

64. One respondent who felt that it should not be included commented that trustee knowledge and understanding should be enforced more rigorously by TPR, and that if TPR has concerns the scheme should be forced to consolidate. Another suggested TPR insist that schemes only recruit suitably qualified trustees.

65. Responses were evenly split as to whether it would be useful to take the open/closed status of a scheme into consideration. Some thought that this was irrelevant, with one commenting that some closed schemes were well run. Others believed that it made sense to consolidate closed schemes. One suggested that consolidation would be in the best interests of members in schemes where there is a greater proportion of deferred members to actives.

66. Only a small number of respondents commented on demographic factors and there was a fairly even split as to whether this should be a consideration. One commented that as value for money is dependent on so many different factors, no further prescription should be necessary. Another respondent felt that the degree of support from the sponsor for unexpected events should be considered, and one suggested that contribution levels should be considered.

Government response

67. We will not include scheme status or demographic factors as part of the value for members assessment.

68. Trustee knowledge and understanding can have a significant effect on member outcomes and we propose that trustee knowledge and understanding is included as a measure of value for members. We note respondents’ views that this area may be difficult to measure. We believe that providing more information in new statutory guidance, together with the existing education, guidance and codes of practice available from TPR, will assist schemes in this respect.

69. TPR will continue to regulate trustees’ compliance with their legal duties, including the requirements for trustee knowledge and understanding. More broadly, TPR will use the information received via the scheme return about the value for members assessments as part of the intelligence they draw on when making decisions about their regulatory approach towards different segments of the market. TPR has made it clear that “If trustees cannot meet the standards we expect, we believe they should wind up and consolidate savers into a better run scheme.”^{[footnote 16]}

70. TPR has also commented that “some trustees put a high value on the fact that they may know the members personally and can provide that recognition and familiarity. Those trustees have to take a step back and ask if that’s actually what members value, and do they value it to the extent that they’re paying more in charges than they should be, and that their funds aren’t necessarily being invested in the best way that they can be.”^{[footnote 17]}

Summary

We propose that the level of trustee knowledge, understanding and skills within the trustee board as a whole will be used as a measure of value for members in the extended value for members’ assessment.

Proposed changes to regulations

71. We propose to make amendments to the Administration Regulations 1996 and the Register of Occupational and Personal Pension Schemes Regulations 2005.

72. This section summarises the changes which will be made to these regulations by the draft Occupational Pension Schemes (Administration, Investment, Charges and Governance) (Amendment) Regulations 2021 which can be found in annex C.

73. We are seeking further views on two issues relating to these draft regulations which are set out in questions Q1 and Q2 below.

Amendments to the administration regulations

74. The proposed regulations would extend the requirements of the value for members assessment for relevant^{[footnote 18]} occupational pension schemes which have been running for at least three years and have money purchase assets of less than £100 millon. Amendments to Regulations 23 and 25 of the Administration Regulations would require trustees of those schemes to complete the more detailed assessment on an annual basis and report on the results as part of their chair’s statement.

75. Further statutory guidance about what trustees should have regard to when completing this assessment will be provided.

76. We propose that the Regulations require trustees to assess value for members across three areas:

• net returns (investment performance)
• costs and charges
• administration and governance

Net returns and costs and charges

77. Net returns and levels of costs and charges have a significant impact on the value of a pension over the period it is invested.

78. These factors are to be assessed relatively in comparison to those of at least three other ‘large’ occupational or personal pension schemes^{[footnote 19]} of which at least one would be willing to accept the members from the smaller scheme should the trustees decide after assessment to wind up and consolidate. We are proposing that a ‘large’ scheme is one with £100 million or more total assets.

79. A relative comparison of costs and charges can be achieved using the information on costs and charges that schemes are already required to disclose. To facilitate effective comparison of net returns, as well as improving transparency across the market, we also propose extending the requirement for disclosures on net returns.

Net return disclosure for all relevant schemes

80. We also propose to require that all relevant schemes, regardless of size, publish net returns for their default and self-selected funds. We propose advising in statutory guidance that net return figures be shown as annual geometric averages and that figures for returns be shown for investment performance from 2015 onwards, where possible. Smaller schemes in scope will then be able to complete a relative assessment of their returns in comparison.

Subsequent amendment to the Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013

81. As a consequence of the amendment to the Administration Regulations in relation to the reporting of the scheme’s net returns on investments, we propose that our amending regulations will also amend Regulation 29A (2) of the Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013 to require the return on investments information to be made publicly available free of charge on a website.

Question 1: We would welcome your views on the reporting of net returns – how many past years of net returns figures should be taken into consideration and reported on to give an effective indication of past fund performance?

Administration and governance

82. We propose to regulate that certain factors of administration and governance be used in measuring value for members.

83. Regulations would require an absolute assessment to be made within the scheme of how it meets the various criteria of good administration and governance standards.

Schemes would not be required to assess this element against three larger schemes as it is more difficult to establish comparable and quantifiable metrics across our diverse DC landscape.

84.The criteria we propose to be assessed are:

• promptness and accuracy of core financial transactions
• quality of record keeping
• appropriateness of the default investment strategy
• quality of investment governance
• quality of communication with members
• level of trustee knowledge, understanding and skills to operate the scheme effectively
• effectiveness of management of conflict of interest

85. Based on assessing the three areas of i) net returns, ii) costs and charges and iii) administration and governance we propose that the scheme will be required via Regulation 23(1)(c)(b) to report overall in the chair’s statement the extent to which the scheme represents value for scheme members. The outcome should be a holistic one but made with regard to government’s statutory guidance.

Amendments to the Register of Occupational and Personal Pension Schemes Regulations 2005

86. The proposed amending regulations will also amend Regulation 3 of the Register of Occupational and Personal Pension Schemes Regulations 2005 to provide that in the annual scheme return ALL schemes regardless of size must confirm their scheme’s monetary value of total assets.

87. For those schemes with assets of less than £100 million and running for at least three years, we propose further amendments to Regulation 3 which will require the trustees or managers to state in their annual return whether they consider, on the basis of the most recent assessment carried out under the Administration Regulations (and the previous year’s assessment, where applicable) that their scheme provides good value for members.

Where the trustees have stated that they do not consider that the scheme provides good value for members, then on the annual scheme return we propose that the trustees must indicate whether they plan to wind up the scheme and, if not, their reasons for not doing so and the improvements they plan to make to the scheme.

Question 2: Do you think that the amending regulations achieve the policy aims of encouraging smaller schemes to consolidate into larger schemes when they do not present good value for members?

Question 3: Do you believe that the statutory guidance increases clarity about the minimum expectations on assessing and reporting on value for members for specified schemes? Are there any areas where further clarity might be required?

Conclusion

We believe that the proposed measures outlined in this chapter will improve outcomes for savers by encouraging trustees to consider consolidating to ensure savers are in well-run schemes that deliver good value for members and that have the scale to invest in a diverse range of asset classes, including illiquids.

The government views accelerating the consolidation of the DC market into fewer, larger schemes as a priority. For this reason, the efficacy of any amendments made to regulations such as the current proposals will be kept under review. If any new requirements do not drive consolidation at sufficient pace, the government will develop legislation to mandate consolidation.

1. Paragraphs 20-36 ↩

2. The Pensions Regulator. DC Trust – presentation of scheme return data 2019-20 ↩

3. Corporate Adviser. Workplace Savings Report. November 2019 ↩

4. Excluding schemes commonly referred to as small self-administered schemes (SSAS) where the members are themselves trustees and executive pension schemes ↩

5. The Pensions Regulator Defined Contribution trust-based pension schemes research survey 2019 ↩

6. Average annual charges for qualifying trust-based schemes broken down by number of members. 0.61% for schemes with 12-99 members and 0.37% - 0.44% for schemes with at least 1000 members. DWP Pension Charges Survey 2016, October 2017, Pension charges survey 2016: charges in defined contribution pension schemes ↩

7. The Pensions Regulator Defined Contribution trust-based pension schemes research: Report of findings on the 2019 survey ↩

8. The Occupational Pension Schemes (Scheme Administration) Regulations 1996 No: 1714 Regulation 23 ↩

9. The Pensions Regulator Managing DC Benefits, value for members ↩

10. The Occupational Pension Schemes (Scheme Administration) Regulations 1996 No: 1714 Regulation 1 ↩

11. The Pension Regulator 21st Century Trusteeship ↩

12. The Pensions Regulator press release: ‘badly run schemes need to improve or consolidate’ ↩

13. The Pensions Regulator blog ‘why we’re pushing pension schemes out of the market’ ↩

14. “relevant scheme” as defined by Regulation 1(2) of the Occupational Pension Schemes (Scheme Administration) Regulations 1996 – broadly, defined contribution schemes ↩

15. A personal pension scheme which is not an investment-regulated pension scheme within the meaning of paragraph 1 of Schedule 29A to the Finance Act 2004 ↩