Phoenix IGC – making sense of legacy pensions.

Phoenix has published its 2022 IGC statement for the period up to 31st December 2021, along with reports for Standard Life and ReAssure , it is one of three statements from the Chair of all three – David Hare.

As Phoenix is in itself a consolidation of numerous life companies, including Abbey Life, the chair of whose IGC was also David Hare, this represents an extraordinary achievement for one man. It is also quite an achievement reviewing what amounts to nearly 400 pages of reports! Much of the introduction to the report is reproduced across all three and for my views on the frustration of the Chair to the FCA’s requirement of the IGC, you may want to refer to my review of Standard Life.

But I am falling into the trap of putting process in front of substance, the Phoenix report is in substance a call for people in Phoenix policies to think hard about what they have. This appears early in the report

CALL TO ACTION: We encourage you to review the charges you are paying and the benefits you receive. You may be able to get better value on the open market.

Here is the Phoenix Value for Money Dashboard.

With the exception of ESG and investment services (presumably services shared), all of the rankings are worse at Phoenix than at Standard life. This however is only possible to work out if you have other IGC reports to hand, which frankly is unlikely to be the case for the average saver.

Which is the problem with VFM assessments based on so many parameters. Here is the Standard Life version – see if you are called to action.

Despite the radically different scorings between the two dashboards , both communicate the same message that Phoenix and Standard Life customers both get good value for money. How can this message be used by consumers to make decisions about which pension  product to use going forward?

And what does going forward mean?

You may have missed this, but it seems that the Phoenix  companies do not have an IGC VFM rating for investment pathways , as Standard Life has. There is obviously a reason for this, though I have yet to find it in the Chair’s Report. Investment Pathways to not appear in a search on the report’s glossary.

Herein is the great difficulty with the regulations, not only surrounding what policyholders can expect from an IGC report, but what they can expert from a workplace or non-workplace pension.

If there are no investment pathways for Phoenix Life customers to follow, then whose pathways should they follow and how can they find information on value for money on pathways? There is a comparison site, on the MaPS website , but it does not offer a VFM comparison, the only comparison being on price.

I am going to give the Phoenix IGC an amber for its VFM assessment – it is probably a brilliantly constructed dashboard and hugely helpful to Phoenix and the FCA, but it really doesn’t help the saver much, and it is the saver who is most in need of help!

Tone and Content

At no point does the IGC report clearly state who it is talking to. We get, throughout the report referees to the various life companies whose policies and practices are being analysed, but despite working through the document methodically, I still do not know what some of the insurers acronyms stand for. The “further commentary” section , which comprises the last 70 pages would be much more helpful if I had an idea of what was being analysed!

That said, this is an amazing document in terms of the scope of its work and the fact that it exists is testament to the IGC’s tenacity in collating so much information.

But I wonder if much of the information contained in it, might not have been better organised into analysis on the IGC website and excluded from the main body of the report which is after all , a means to assess value for money.

The tone of the document is even and measured and at times it is engaging, but it’s very hard for policyholders to consider the IGC as a source of guidance on how to go forward. It needs a much clearer focus on “what members could do, and should do”.

I give the Phoenix IGC an amber for tone and content.


It is an almost impossible task for one IGC to provide oversight over such a wide number of products, funds and insurers. The Phoenix IGC is also involved in doing this for the other legacy companies within ReAssure and for Standard Life. Phoenix has 13m policies and pretty well owns our pension legacy.

If it is to persist with three IGCs , then surely it should not shoulder responsibility for governance on one Chair and a handful of independent experts.

Though this report is effective in showing us the scale of the remit, it is difficult to see how the IGC can be expected, with such stretched resources and duties elsewhere, to do their job effectively. I will however give the IGC a green for doing its heroic best for its savers.

About henry tapper

Founder of the Pension PlayPen,, partner of Stella, father of Olly . I am the Pension Plowman
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1 Response to Phoenix IGC – making sense of legacy pensions.

  1. Peter Beattie says:

    Henry. Do your comments give any reassurance about those of us with Standard Life and Reassure interests that their investment is still ‘prudent’. If not what should one do?

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