How IGCs have performed this year and since 2015


IGCs were set up by life companies offering workplace pensions at the insistence of the FCA. Their principal job is to assess whether the workplace pension(s) they oversee are providing policyholders with value for money.

By and large they do this one way or another. But it’s very hard to find consistency in how they go about this. Rather than agreeing a consistent definition of value for money, they have each created their own definition and their individual way of assessing it.

This has led to inconsistency and confusion. The FCA – in conjunction with the Pensions Regulator and at the behest of the DWP, has imposed a three pronged assessment based on charges, performance and service. This could be further simplified to make value for money the experience you receive and the outcome you get for the money you pay.

With the 2022 reports (published in Sept 2023) we are beginning to see greater consistency in value for money reporting.

These are the ratings given to all IGC reports for the past four years

Key – green is good, amber is ok and red is bad

Over time trends become clearer. Certain IGCs have been more effective, delivered better reports and paid more attention to value for money than others.

These are the ratings going back to 2016

These are the opinions of one person and subject to personal bias. That doesn’t mean that those opinions aren’t valid, but it asks for challenge.

The “G” in ESG

In this year’s reports , I have not commented on sections of the report that talk of the provider’s policies on ESG and how they are integrated into workplace pensions. The issues of stewardship, engagement and most importantly of sustainability are critically important but are aspects of the analysis of outcomes and experience that underpin VFM.

In time, the ESG sections will be integrated into the VFM reports rather than being treated as innovation (which they aren’t).

The G in ESG is of course what Governance Committees do. But because IGCs are neither part of the occupational pension framework nor properly part of the wealth management industry, their work is largely ignored.

The most important work of IGCs is on behalf of the non-advised members of workplace pensions that aren’t under the auspices of the Pensions Regulator.  These people are stranded between the high level scrutiny of institutional governance and the granularity of independent advisers. The IGCs are also critically important to employers who choose GPPs as their workplace pensions.

If it isn’t measured

Thanks to the IGCs who sent me their reports.  If you want to read the individual report on your IGC, you can find the link below


Provider  Review Link
 Royal London
Legal & General
Scottish Widows
Standard Life
Asset Managers
Legacy providers
New breed SIPPs
HL Vantage

About henry tapper

Founder of the Pension PlayPen,, partner of Stella, father of Olly . I am the Pension Plowman
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2 Responses to How IGCs have performed this year and since 2015

  1. B M says:

    Virgin published their IGC report on 28th September 2023 – it is not under a GAA.

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