Transparency data

SAB meeting minutes: 1 April 2025

Updated 27 January 2026

Applies to England and Wales

45th  Meeting, 01 April 2025, 10:30 – 14:30

Draft Minutes

1. Members present:

Independent Chair: Julia Mulligan (secretarial note - chair has now departed)

Secretariat: Chris Moore

Police Federation of England and Wales (PFEW) – Attending as Observers:

• Paul Turpin 

Police Superintendents’ Association (PSA):

• Dan Murphy

• Stuart Kehily

Chief Police Officers’ Staff Association (CPOSA):

• Shabir Hussain (SAB Member)

• Gareth Wilson

National Police Chief’s Council (NPCC):

• Clair Alcock

• Claire Neale

• Kevin Courtney

Home Office (HO):

• Helen Fisher

• Sara Alderman  

• Simon Primmer

National Association of Retired Police Officers (NARPO):

• Steve Wilcock

Superintendent’s Association of Northern Ireland (SANI):

• Amanda Ford

Association of Scottish Police Superintendents (ASPS):

• Stewart Carle

Department of Justice, Northern Ireland (DoJNI):

• Antonia Hoskins

Police Service of Northern Ireland (PSNI):

• Stuart Griffin 

Police Federation Northern Ireland (PFNI):

• Liam Kelly

Scottish Police Authority:

• Sharon Dalli

• Alasdair Corfield

Scottish Police Federation (SPF):

• David Kennedy

First Actuarial:

• Craig Moran

• James Allen

Government Actuary Department (GAD):

• Charlotte White

• Michael Scanlon

Scottish Public Pensions Agency (SPPA):

• Alan Wilkinson 

• Elle O’Kane 

• Mhairi Kinnaird  

2. Welcome and Apologies

1. The chair welcomed everyone to the meeting. Apologies were received from Sarah Reid (Northern Ireland Policing Board). The chair said this was Helen Fisher (HO), Clair Alcock (NPCC) and the Chair’s last meeting.

3. Minutes of the meeting of 14 January 2025

3.1 Action Point 1: Secretariat to publish finalised minutes of 14 January 2025 on webpage.

Action Log of 14 January 2025.

3.2 Action Point  2: (Opt-Out Update) HF to send the update by the end of the week, following which the SAB will write to the Home Office.

2. Helen Fisher (HO) explained that information had been released in parts as it became available and confirmed additional details were circulated the previous week. She acknowledged the resulting confusion and committed to issuing a consolidated update.

3. Helen confirmed that review remains ongoing for certain member cohorts not reinstated in the last accrued legacy scheme. She said the update was not a change of position but an effort to clarify legislative interpretation.

4. Dan Murphy (PSA) confirmed the SAB had written to the Minister on this issue. He inquired whether a response had been received.

5. Helen Fisher (HO) replied that no response had yet been received but confirmed she would provide a clearer update by close of tomorrow, distinguishing which members could be reinstated under existing powers.

6. David Kennedy (SPF) raised concerns about individuals auto-enrolled and later leaving, noting that under current interpretation they could be unfairly excluded from legacy reinstatement.

7. Helen acknowledged this was a significant point and confirmed any changes to legislation would require formal consultation, and this issue should be included in that process.

3.3 Action point 3: JV to liaise with CA to email out to the necessary groups again, including the identification of cohorts and data returns.

8. Jeremy Vaughan (NPCC) reported that he had convened an Extraordinary Chiefs Council since the last SAB meeting. There was high attendance, and a clear update was provided on deadlines and scheme manager responsibilities.

9. He expressed satisfaction with the improved understanding and engagement of scheme managers.

10. He held informal discussions with some Chiefs who were struggling, either due to data limitations or internal challenges, and received positive responses.

11. Clair Alcock (NPCC) echoed Jeremy’s points and confirmed all scheme managers had received the necessary information and follow-up support where required.

12. She highlighted that the scheme’s local administration required tailored support for underperforming areas.

Jeremy Vaughan (NPCC) added that out of the 43 scheme managers, performance naturally varies, but individual follow-ups had helped raise the overall standard.

3.4 Action Point 4:  DM to pick up data gaps with CA

13. Dan Murphy (PSA) noted he had not understood the action when reviewing the minutes. The Chair proposed closing the item and this was accepted.

3.5 Actions 5–7

14. Confirmed by relevant parties that all other actions were completed and marked as closed.

4. Outstanding Actions from Previous Meetings - 08 October 2024

4.1 Action Point 2: Helen Fisher (HO) committed to providing an update on the PMAB guidance document review at the January SAB meeting

15. Simon Primmer (HO) reported ongoing engagement with stakeholders and medical professionals to update out-of-date guidance for the Police Medical Appeal Boards.

16. The next steps involve reviewing collected feedback and conducting engagement sessions. The anticipated timeline for resolution was six months.

17. The Chair confirmed the action was completed and would return to SAB with updates in due course.

18. The Chair noted actions 3, 5, 6 were all to be addressed in the agenda or through supporting papers and closed the actions.

5. Outstanding Actions from Previous Meetings - 28 March 2024

19. The Chair noted actions 2, 5 were both to be discussed within the meeting agenda and closed the actions.

6. Future board arrangements

6.1 Item 5: Future of the SAB – Governance Discussion

20. The Chair introduced the NPCC-prepared paper as an informal contribution to governance reflection, prompted by upcoming leadership transitions in key areas.

21. Clair Alcock (NPCC) explained that with governance introduced ten years ago (April 2015), now was an appropriate moment for review. The discussion paper was designed to help incoming leadership to reflect on effectiveness, representation, and the Board’s statutory duties. She emphasised the review was consistent with other public sector governance practices.

22. Jeremy Vaughan (NPCC) expressed concern that SAB was not currently fulfilling its statutory advisory role to scheme managers or the Secretary of State.

23. Alan Wilkinson (SPPA) and Stewart Carle (ASPS) voiced support for Scotland’s continued observer role. They emphasised the value of UK-wide collaboration.

24. Iiam Kelly (PFNI) challenged paragraph 27 of the NPCC paper, which implied observers added limited value. He provided historical context, noting SAB and UKPPCF meetings were once separate but aligned in agenda and became merged under the previous chair due to repetition in both meetings.

25. Sharon Dalli (SPA) added that merged meetings had diminished inter-nation discussion and that separate meetings facilitated better knowledge exchange.

26. The Chair stressed that SAB needs stronger leadership and more allocated time to deliver its statutory duties. She proposed that the next Chair’s role be better resourced, following the Fire SAB model. The Chair added that Tom Appleyard had stated that there was no resourcing for the SAB.

27. Shabir Hussain (CPOSA) stated that when SAB was set up Peter Spreadbury confirmed that the SAB could draw on specialist assistance as and when it was required and that needs to be reaffirmed. Secretarial Note:Shabir Hussain subsequently copied Peter Spreadbury’s letter to Tom Appleyard.

28. Jeremy Vaughan (NPCC) proposed a joint letter to the Secretary of State, stating clearly that the SAB, as currently structured and funded, is not functioning.

29. The outgoing Chair confirmed a willingness to co-sign a letter. Also referencing similar concerns in her resignation letter.

30. Alan Lees (NARPO) warned that, without direction and funding, SAB risks becoming ineffective and irrelevant, much like previous pension forums.

31. Shabir Hussain (CPOSA) reminded SAB that the terms of reference required formal review by the chair in October 2024, it was not for any other party to launch their own, they ought to be contributing to the chair’s request. He recommended initiating that formally through the next SAB Chair.

32. Andy Tremayne (APCC) welcomed the discussion paper and added that changes in responsibility may mean dual Chair roles (PAB and SAB) are no longer realistic.

33. Jeremy Vaughan (NPCC) clarified that the NPCC would send a separate letter to the Secretary of State, not on behalf of SAB, but highlighting the lack of effective advisory function. The Outgoing Chair and Jeremy Vaughan to submit individual letters.

6.2 Action Point 2: Outgoing Chair and Jeremy Vaughan to submit individual letters to the Home Secretary regarding SAB structure and funding concerns

Item 6: Advice given to the scheme manager or local pension board

34. Shabir Hussain (CPOSA) raised the issue of interest arising (for underpaid contributions) from late RSSs.  He said it was morally wrong to bill the officer through no fault of their own, when the force’s administrator is responsible for the delay.  He stated that the Treasury Directions gave forces permission to waive the interest accruing between 1 April 2025 and the date the RSS was issued.

35. Jeremy Vaughan (NPCC) said it cannot be right that members are billed.  He added that he had shared his force’s position with other chief constables.

6.3 Age Discrimination Remedy Update

36. Clair Alcock (NPCC) introduced the update on age discrimination remedy implementation. He noted the first milestone for remedial service statements (RSS) had passed on 1 April 2025. She acknowledged widespread challenges across the public sector, including delayed policy clarification and legal interpretation, affecting all schemes, not just police.

37. She noted that compared to schemes like NHS and Fire, police are further ahead, though not where hoped.  Clair Introduced Kevin Shiel (XPS) to provide data and commentary for the 32 forces under XPS administration.

38. Kevin Shiel (XPS) provided a detailed verbal report accompanied by a slide deck (shared post-meeting):

As of 30 March, 84% of Immediate Choice RSS had been issued. 99% completion on active Annual Benefit Statements RSS; remaining cases due to missing or questionable data.

Deferred RSS stood at 70% completion, with work ongoing.

• XPS has run calculations for 100% of members where full data is available.
• He explained tolerance checks, manual intervention requirements, and the impact of inherited data issues.
• He highlighted discrepancies from schemes taken on mid-remedy period and problems like missing pension sharing orders.
• He confirmed specific forces like Wiltshire faced greater delays due to historic data issues.
• He outlined escalation processes for vulnerable or financially affected members.
• He described categorisation of members still awaiting statements by retirement type (e.g. death in service, ill health) and calculation status.
• He emphasised commitment to data accuracy over speed to protect member outcomes.

Discussion acknowledged:

• Positive engagement from scheme managers.
• Challenges with older datasets and inherited administrative gaps.
• Importance of continued collaboration and resourcing to complete the process.
• Recognition that some members could see reductions in benefit, requiring sensitive handling.

39. Shabir Hussain (CPOSA) questioned accountability for historical errors in data from forces onboarded mid-remedy period. Asked whether XPS or the force held liability.

40. Kevin Shiel (XPS) responded that liability decisions rest with the scheme manager. XPS is working with forces and NPCC to identify the nature and origin of data issues, but resolution depends on force ownership.

41. Clair Alcock (NPCC) clarified that under regulations, the current scheme manager bears full responsibility for the accuracy and quality of scheme data, regardless of administrator history.

42. Michael Scanlon (GAD) queried whether data issues arose from misaligned contribution and pension information, as administrators rely on the GAD-provided contribution adjustment calculator.

43. Kevin Shiel (XPS) confirmed problems included non-submission of calculators and data integrity issues (e.g. duplicate or missing lines), which needed correction before accurate calculations could be issued.

44. Michael Scanlon (GAD) gave an update on GAD’s national work concerning pension sharing on divorce:

45. He acknowledged lack of policy clarity has delayed accurate RSS delivery for members affected by divorce during the remedy period.

46. GAD is finalising guidance on these complex cases, including manual support for current divorces and retrospective cases.

47. Draft guidance has been shared and is expected to be finalised within the next three months.

48. Helen Fisher (HO) expressed thanks to XPS and GAD. She emphasised the government recognised how exceptionally complex the remedy process is and that administrators’ caution to ensure accuracy is not failure but diligence. She highlighted that police are leading the way across the public sector in RSS delivery.

49. Clair Alcock (NPCC) shared updated figures received that morning. The Met had issued 74% of ICRSS (~19,000 officers). A further 15% (approx. 3,982 members) had pre-identified issues or extensions under Section 29. Only 11 statements were awaiting imminent publication.

50. Alan Wilkinson (SPPA) reported Scotland’s performance. 98% completion for active and deferred ABS. 53% completion for Immediate Choice RSS, but rising rapidly from only 1,000 statements issued a week earlier.

51. Antonia Hoskins (DoJNI) noted ABS delivery in Northern Ireland was on time, but RSS completion had been hampered by local complexities. The exact figures were unavailable.

6.4 Letter to Local Pension Boards

52. Clair Alcock (NPCC) noted the draft letter intended for local pension boards, aimed at strengthening assurance and transparency across local governance.

53. She clarified that local pension boards have a statutory responsibility to assist scheme managers in securing compliance, making them the appropriate audience.

54. Clair noted the importance of understanding whether boards have effective procedures for Section 29 decisions, breaches, IDRP procedures, compensation policies, and record-keeping (especially in line with The Pensions Regulator’s guidance). She noted past inconsistencies and varying awareness levels across boards. Data quality issues exposed by remedy implementation reinforced the importance of accurate record-keeping. She reiterated the letter’s aim to gather information on local policies, breach handling, and readiness for pensions dashboards.

55. The Chair supported the initiative, acknowledging that past engagement revealed highly variable levels of preparedness and capacity among local boards. She Invited members to send feedback on the draft letter via email due to its late circulation.

56. Dan Murphy (PSA) noted he had not yet read the letter due to its last-minute distribution.

57. The Chair confirmed that written feedback is welcomed, with the intention to finalise and send the letter by 14 April, before she ends post.

6.5 Action Point 3: SAB members to submit feedback on draft letter to Local Pension Boards by 14 April.

6.6 Communications to members who retire from the 2015 scheme after age 55 but do not choose to take 2015 benefits immediately – impact of actuarial factors

58. Craig Moran (First Actuarial) presented a paper clarifying issues around early retirement for deferred members, stating that it is not about traditional “early retirement,” but rather a systemic disparity in pension age treatment.

59. He said deferred members have their normal pension age aligned to state pension age (66–68), unlike active members, whose normal pension age remains at 60. This disparity applies across the 1987, 2006, and 2015 schemes but is becoming more visible due to shifts in police career patterns.

60. He highlighted the financial impact. Members leaving service post-55 and deferring benefits can lose a substantial portion of their pension if later taken before state pension age, due to harsher actuarial reductions.

61. The proposed next steps were data gathering, he suggested identifying how many members are deferring 2015 scheme benefits after age 55. Valuation data could reveal this cohort.

62. A review of communications, he proposed reviewing XPS (and other administrators’) communications to ensure members are clearly informed of this risk.

63. Craig Moran (First Actuarial) recommended updating scheme websites and using staff reps to spread awareness. He acknowledged McCloud-related communications may have crowded this out. He said this is not a new issue but one newly relevant due to changing retirement behaviours.

64. Dan Murphy (PSA) and Sharon Dalli (SPA) confirmed that concerns about actuarial reduction have been raised in both England and Scotland. Sharon noted that original messaging was clear in 2015, but recent communications have become confused. Dan highlighted that some members over 55 may defer without understanding the significant financial impact.

65. The Chair asked if the first step should be to collect and assess current communications from XPS and others.

66. Craig Moran (First Actuarial) confirmed that XPS should be asked first due to their wide coverage. If their messaging is appropriate, it should be extended across all administrators.

67. Clair Alcock (NPCC) proposed adding a new FAQ to the NPCC website outlining outcomes for members retiring before and after age 55. This can then inform administrator messaging.

68. Shabir Hussain added that the Home Office ought to update the members’ guide.

69. Helen Fisher (HO) supported the idea and emphasised that communication clarity is critical, regardless of how many members are affected.

70. Michael Scanlon (GAD) confirmed GAD is collecting 2024 valuation data and will explore whether it can help quantify the size of the impacted group.

6.7 Action Point 4: Michael Scanlon (GAD) to confirm whether any additional information can be provided from the valuation data on the number of members leaving service after age 55 and not immediately retiring.

6.8 Action Point 5: NPCC to draft and publish a new FAQ on outcomes for members retiring before and after age 55 and for the Home Office to update the members’ guide.

Pension dashboard implementation

71. Claire Neale (NPCC) delivered a detailed overview of preparations for pension dashboard compliance, reiterating the deadline for public sector scheme connection as 31 October. Key developments include a dedicated checklist tailored for the police pension context, with responsibilities assigned across scheme managers, administrators, and local pension boards. Alignment of dashboard data with the Annual Benefit Statement, which projects to age 60 to ensure consistency across platforms. The finalisation of a standardised data set now being implemented by administrators and ongoing development of a communication strategy that will outline clear messaging tailored for different audiences including members and senior leaders.

72. Shabir Hussain (CPOSA) raised whether schemes could delay connection using legal exemptions under Regulation 17. Claire Neale (NPCC) responded that a sector-wide extension had already been secured and the deadline had since passed.

73. Helen Fisher (HO) asked if dashboard implementation risked diverting resources from McCloud. Claire Neale (NPCC) clarified that the workstreams were separate and typically handled by different teams due to the technical nature of dashboard connection versus business-as-usual pension calculations.

74. Clair Alcock (NPCC) recommended the SAB focus on the quality of member data and matching logic, emphasising lessons from the Annual Benefit Statement issues during remedy implementation. She cautioned that while administrators are focused on technical delivery, end-user experience must also be prioritised.

75. The Chair asked whether there were any implications for SAB to action. Clair Alcock (NPCC) suggested the Board consider requesting information from schemes about their matching rules and data reconciliation work as part of preparation. She stressed that dashboards could prompt a new wave of data scrutiny from members and urged a proactive approach.

76. The Board agreed that a reminder to local pension boards about record-keeping and compliance with The Pensions Regulator’s data standards should be considered as part of the SAB’s upcoming correspondence.

6.9 CPI Mismatch draft letter to HO and next steps

77. Clair Alcock (NPCC) introduced the long-standing issue of CPI mismatch, where disparities between the CPI rate used to uprate pensions and the CPI rate used for annual allowance calculations could financially disadvantage members. Although less visible when inflation is stable, recent fluctuations between 3% and 10% have significantly raised the risk of material impact. She explained that this issue pertains to benefits earned after 1 April 2015 in the CARE scheme and would increase in significance over time. A draft letter to the Home Office requesting formal action was presented.

78. Craig Moran (First Actuarial) added that the mismatch may benefit some members in certain years but penalise them in others. The issue does not affect all schemes—fire and armed forces use different uprating measures, and NHS and LGPS have already resolved the mismatch. Craig emphasised this was the right time for police pensions to resolve the matter, before it becomes more entrenched.

79. Simon Primmer (HO) confirmed the Home Office is committed to reviewing the matter in the 2025–26 financial year and found the draft letter and actuarial analysis supportive. He noted implementation timelines would need careful consideration in light of competing administrative priorities.

80. Shabir Hussain (CPOSA) argued that the delay had already resulted in members—particularly senior officers—paying higher taxes unnecessarily. He insisted that SAB had only agreed to defer in 2023 because of remedy, not as a long-term avoidance of action. He proposed April 2026 as the target implementation date, with any later timelines risking further losses for members.

81. Gareth Wilson (CPOSA) supported the April 2026 target and shared statistics with the Chair highlighting confidence and attrition issues related to pension uncertainty. He described the current moment as critical for regaining member trust and urged timely action.

82. Helen Fisher (HO) welcomed the discussion but reminded the group that a formal consultation must precede any implementation. She flagged ongoing McCloud work as a legitimate constraint, and warned against overloading administrators and software providers.

83. Clair Alcock (NPCC) offered a note of caution, observing that early implementation could lead to increased commercial burdens. Since police pensions are locally administered and funded, earlier implementation may require additional software development costs at the force level.

84. The Chair concluded that while resource constraints must be acknowledged, the Scheme Advisory Board should be clear in its position. The draft letter would be revised to specify April 2026 as the target implementation date and the Chair welcomed any written updates from the Staff Associations.The Chair noted that if administrators or the Home Office could not meet that timeline, they would need to respond explaining why.

6.10 Action point 6: The Chair to revise and circulate the draft letter to be sent to the Home Office for approval, specifying April 2026 as the SAB’s recommended implementation date and requesting a formal review during the 2025–26 financial year. Secretarial note: The Staff Associations conveyed their amendments to the chair and subsequently copied it to Simon Primmer.

6.11 NI and Scotland update

85. Mhairi Kinnaird (SPPA) reported that Scotland had introduced amendment regulations in response to the 2020 valuation, which increased member contributions to address a shortfall.

86. Changes to ill health eligibility were introduced prospectively from 1 April, including removal of the two-tier member contribution structure previously found to be discriminatory.

87. SPPA is currently considering retrospective amendments for members affected before 1 April.

88. Antonia Hoskins (DoJNI) noted that their Minister had agreed in principle to consider retrospection for the 2015 scheme ill-health cases only at this stage. .

89. Contributions changes had already been implemented previously; future adjustments awaited the outcome of the upcoming valuation.

6.12 Local pension boards update

90. The Chair asked for updates on local pension boards.

91. Clair Alcock (NPCC) stated that the joint pension board currently lacked a chair and was therefore inactive. XPS is supporting recruitment for a new chair, funded by participating scheme managers.

6.13 NPCC single shared services scheme manager updates and next steps

92. Clair Alcock (NPCC) provided a progress report on the implementation plan for the shared services scheme manager:

93. Three strands were underway: structural and employment arrangements (noting NPCC cannot employ staff directly, local project board scoping what should be centralised or retained locally; and governance planning, though this third strand is currently paused.

94. The governance aspect will focus on how the shared service interacts with SAB and local pension boards and what structures will ensure accountability.

Letter from HMT to NPCC on compensation

95. Clair Alcock (NPCC) highlighted a letter from HMT in response to NPCC’s concerns about the compensation mechanism.

96. The correspondence confirmed that there is no end date to the compensation requirement and acknowledged the long-term operational and cost implications.

97. HMT also clarified that HMRC’s digital service may incorrectly identify amounts as “compensation” due to its basic calculation function. These errors could result from historical scheme issues unrelated to Remedy.

98. Guidance has been issued to scheme managers on how to interpret these digital service outputs and determine legitimate compensation cases.

99. Dan Murphy (PSA) asked if this guidance would be shared; Clair Alcock (NPCC) confirmed it was likely to be published in a recent bulletin and would ensure it is recirculated.

7. Any Other Business

100. Shabir Hussain (CPOSA) raised a point about a typo in a document on the NPCC website form last year regarding Pension Taxation and said it was unacceptable that it remained unchanged when he had pointed out the errors at the time of publication.

110. Clair Alcock (NPCC) confirmed it related to NPCC advice, not SAB business, and acknowledged the typo would be corrected.

102. Dan Murphy (PSA) noted a discrepancy in remedy mapping documentation circulated by NPCC, which differed from the PSA’s version with proposed solutions.

103. Clair Alcock(NPCC) acknowledged the oversight.

104. The Chair thanked members and closed the meeting