
Christos Christou is a PMI Professional Trustee and has produced a proposal to the Pension PlayPen . For more details about Christos scroll to the bottom of this blog.
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The Challenge
• Based on DWP’s impact assessment (Sept 2024), the Government’s surplus extraction framework will mobilise around ~£8.4bn over 10 years.
• It is tax-leaking, complex, requires new regulations and first extractions are not expected until 2027.
The Complementary Policy Enhancement Solution
• Raise the cap on sponsoring employer securities from 5% to 10%, but only for schemes in surplus on a low dependency basis.
• Incremental headroom applies only to new securities issuance, ensuring fresh capital flows to employers for productive investment;
The Impact
• Creates ~£50bn headroom within DB pensions in surplus on low dependency basis (out of £1.24tn total DB assets as of Sept 2024), a headroom figure that TPR could further refine with scheme-level granularity.
• Realistic mobilisation: ~£20–30bn, triple the government’s current projections, with no tax leakage.
• Strengthens sponsor balance sheets, improving member security.
The Safeguard
• Only schemes in surplus on low dependency qualify.
• Assets remain within the pension scheme
• Trustees retain full fiduciary control.
Mobilisation Scenarios
Scenario Take-up Utilisation Mobilisation
Conservative 40% 60% £12bn
Base 50% 80% £20bn
Ambitious 75% 80% £30bn
Maximum 100% 100% £50bn
Timeline
• Can be included in the upcoming Pensions Bill.
• No new regulatory guidance required.
• Deliverable in 2026 with the passage of the Pensions Bill
Conclusion
A simple legislative adjustment could:
1. Unlock £20–30bn of productive finance.
2. Accelerate delivery of the Mansion House agenda. 3. Protect members through actuarially grounded safeguards, as low dependency avoids covenant- related judgements. 4. Strengthen UK employers and boost growth.
