Assessment of 2021 IGC reports – a boring read but an important one!

Despite the efforts of the FCA to make IGC reporting more relevant to ordinary savers, I found this crop of IGC reports were bland and unambitious in their reporting of VFM. No IGC suggested that  value for money was not achieved, even where the value generated by members of the GPPs under scrutiny was clearly low.

Where backward assessment provided positive news, these were used. Where they provided bad news, they were skipped over and we were given speculative assessments based on a rosier view for the future.

The process – started for the 2020-21 reports – of showing charges based on the employer has been universally dropped. Even Aegon, who had done this properly, has now stopped doing this . This means that a meaningful assessment of benchmark charges for use by employers , has gone backwards.

Instead we have long and turgid homilies on ESG and page after page of appendices – listing in tedious completeness, the transaction costs of the various funds.

The general observation is that the shorter the IGC report , the better, one report topped 150 pages this year , the shorter reports which proved most effective (Fidelity, Aviva. Hargreaves Lansdown and Aegon) were less than a third that.

Another sorry feature of this year’s reports was the absence of any transparent benchmarking. Most IGCs subscribed to the Redington benchmarking service but none published the results (presumably this was pre-agreed). The point of benchmarking is to give those who read these reports – supposedly the members – an insight into what they are getting for their money. Instead, the Redington assessments (universally good) were mentioned so far up the ladder of abstraction as to be perfectly useless.

There are positives and I’ve mentioned some of the better reports, but my overall observation is that the IGC report is more than ever an exercise in compliance and we are moving further away from their original point , which was to hold provider feet to the fire.

The reports are all available via links to IGC websites or microsites

Aegon IGC report link is here

Aviva IGC report link is here

Fidelity IGC report link is here

Hargreaves Lansdown IGC report is here

L&G IGC report is here

Phoenix IGC report is here

Prudential IGC report is here

ReAssure IGC report is here

Royal London IGC report is here

Scottish Widows IGC report is here

Standard Life IGC report is here

Vanguard IGC report is here

Virgin Stakeholder IGC report is here


My reviews of these reports produced this year (in alphabetical order)

Aegon IGC report – Perversely going where no IGC has been before   

Aviva IGC report A fierce battle to say relevant

Fidelity IGC report – Focussing on what matters to pension savers

Hargreaves Lansdown IGC report  A peculiarly engaging report

L&G IGC report- IGC report falls short

Phoenix IGC Report – making sense of legacy pensions 

Prudential IGC report – report on an omnishambles

ReAssure IGC report – there can be value at the bottom of the barrel

Royal London IGC report- dour, impenetrable but effective

Scottish Widows IGC report  – beyond the swirling cape

Standard Life IGC report – too long, too angry and wrong

Vanguard IGC report – leads the pack in more ways than one

Virgin Money Stakeholder IGC report – a disappointing anti-climax

A number of IGCs are no more, including those of Black Rock, Friends Life, Abbey Life and most recently Zurich, Old Mutual, B&CE.

Zurich’s IGC has been downgraded to a GAA (Governance Advisory Board). Other GAAs that I hope to review in November include Pension Bee, SJP , Utmost and NFU mutual. If you know of or manage a GAA I do not know of, and want it reviewed, please mail me at

How did they rate?

These are the last three year historic ratings (note the 2021 report was published April 2021 and related to April 2020 to the end of the calendar year

IGC report ratings for 2021 reports (published Sept. 2022)

Some closing thoughts

The IGC reports are still struggling to provide a proper assessment of the value their providers have offered their members for the money that has been saved.

With three providers, I take issue with the VFM assessment, which I see to be wrong.

Historic information is important, speculation about future VFM is not what people want or what the FCA is asking to be provided

Benchmarking is not being carried out in an open way and seems more for the benefit of the provider than the saver

The IGCs are reporting in a much better way though I’m sorry to see homogeneity developing in the over use of photos and most reports are too long.

The IGCs are by and large effective in chivying their providers, the lackadaisical complacency of the early years seems to have gone (though L&G and Scottish Widows could try harder).


A statement about assessment of Standard Life’s IGC report

In my original report about David Hare’s Chair statement I concluded that

.. I simply cannot accept this value for money assessment which is neither compliant or accurate.”

I have retracted this statement as the IGC report is clearly compliant with the FCA’s COBs rules. My remarks should better have addressed the spirit rather than the letter of regulations,

I was also unnecessary personal in my comments about the style and content of the report

I am surprised and a little shocked by the latent anger within this report…” and “But the anger in the report isn’t acute, it’s a kind of sullen lurking anger that he and his committee are being railroaded down a view of value for money he does not agree to.

These opinions have been challenged by David Hare and I withdraw them recognising that they may damage his public and professional integrity, as well as that of the IGC.

I have placed an apology to David and the IGC on the original blog and repeat that apology here – sorry.


About henry tapper

Founder of the Pension PlayPen,, partner of Stella, father of Olly . I am the Pension Plowman
This entry was posted in pensions and tagged , , , , , , , , , , , . Bookmark the permalink.

1 Response to Assessment of 2021 IGC reports – a boring read but an important one!

  1. Pingback: Time for the FCA to review its lifestyle guidance ? | AgeWage: Making your money work as hard as you do

Leave a Reply