A CDC Superfund? David Fair’s “end-game” is confusing.

Posted on December 10, 2025 by henry tapper

I am confused by this paper from David Fairs. Is it really a  personal submission or will it be read as an LCP report?

You can download this epic idea here . Or you can read LCP’s briefing to those on linked -in below

LCP Partner David Fairs has submitted a proposal to the Pensions Commission for a CDC consolidator or superfund.

His paper explores whether it would be beneficial for transfers to be permitted from Defined Benefit arrangements into a CDC pension arrangement and whether a CDC Superfund would be an enhancement to current end game options.

The paper highlights that some of the advantages of DB to CDC transfer are for employers it removes underfunding risk from the employer and means CDC can be accounted for as a DC arrangement, for members it will mean a substantive increase to members benefits as well as more flexibility on how benefits are received and for Government the nature of the funding approach will mean higher allocation to growth assets and ability to invest assets for longer time horizons.

CDC consolidation could create economies of scale allowing lower per member costs of administration and governance. Larger fund sizes will also allow access to investment opportunities and will create the governance budget to invest in a wider range of assets.

David Fairs, Partner at LCP, commented:

“In some respects, a superfund can act as a bridge between the two options open to trustees: run-on or transferring the scheme to superfund or buying out benefits with an insurance company.

Current legislation in the UK prevents a bulk transfer from a defined benefit pension scheme to a CDC arrangement. I believe that there are potential benefits for employers, members and the Government to looking at CDC as a consolidator or superfund.”

For the Pension Commission yes but quietly!

Do not think that scars from pension mis-selling have healed, they are still open.

Ten years ago we started to see DB schemes liberating themselves into wealth pots, this reached its peak for BSPS members  in Scunthorpe and Port Talbot but it happened around the country, people exchanging pensions for pots that make little sense to them  today. That’s why the next step after Retirement CDC is a retail product that allows people to exchange unwanted pots (many from DB) for CDC pensions.

But to confuse those implementing UMES and Retirement CDC with those  deciding on an end-game of annuity and  superfund is to glut our appetites – I fear we will become sick of it all

LCP and David have so far cleansed the appetite of those who are trying to get CDC in place and those trying to get DB schemes to run on. Let us digest what we have before bringing another course!

I do believe that  a CDC superfund could and should happen and (like Andy Young has told us) that a CDC superfund could and should be run by the state (as the PPF is).

But please, David and please LCP, can you have this conversation elsewhere, not while a  consultation on CDC is going on.

We already have our CDC roadmap and this is it. Let us get on with doing it. Please don’t risk a car crash on this road (map).

The place for this exploratory (and extraordinary) thinking is not in discussions of how we get CDC done, it is with the Pension Commission (PC2) as we now call it. It is for a private conversation not a public debate, whether this is through a David Fairs  or an LCP paper.

Can such a respected actuary (and friend) please let the two CDC proposals dawn? A new CDC pension superfund is for a private conversation for the moment.

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The pension industry will leave it till 2029 , hoping CDC fails

Posted on December 10, 2025 by henry tapper

In focus: Green light for retirement-only CDC

Minister for pensions Torsten Bell says:

“Too often people approaching retirement are left navigating complex choices and shoulder risks they shouldn’t have to face alone. By expanding CDC to more employers and consulting on retirement CDC, we are helping build a fairer pensions system that gives people confidence their hard-earned savings will last, and they can enjoy their retirement.”

Gill Wadsworth, an old style journalist I grew up with, is given the job of telling Corporate Advisers what is happening. I suspect they know but don’t believe it’s happening.

Here is Gillian talking with an adviser, for whom CDC appears to start not end with “Retirement CDC“.

Since the government is only looking to occupational schemes to offer retirement-only CDC, the significant scale and operational demands mean they will largely be the preserve of master trusts.

However, given the potential operational and administrative complexities of offering retirement CDC, even the master trusts are a way off demonstrating their capabilities in this area.

Mark Futcher, partner and head of DC pensions at Barnett Waddingham, says: “Operational readiness also matters. Administration and governance frameworks for CDC are still developing and will require investment and bespoke solutions.

Before widespread adoption, the industry needs to ensure those systems are robust and scalable.”

That’s true, that’s why the timeline for CDC is so long. Royal Mail began its discussions in 2017, 8 years ago. Here is the timeline going forward. Here is the Roadmap for CDC and you will note we have four years before we see Retirement CDC (the one that offers DC savers – not CDC savers- their chance of enhancement in their pensions).

All the action for Retirement CDC schemes happens in 2028 with the DWP sensibly curtailing the chart so as not to time the launch of conversions of pots from DC schemes till another application has been approved by “prospective” Retirement CDC schemes.

And here is the Corporate Adviser contingent moaning that they can’t get on with planning until they have more from TPR by way of guidance

“It is only with visibility of the entire regulatory regime that any prospective provider can judge whether they can introduce scalable CDC schemes to the masses – and in a way that is commercially viable.”

What is this latest whinge about? You can pick your expert from the usual suspects, here is the latest whinge.

“We are still awaiting a consultation from TPR on its extended CDC Code. This includes the potential need for TPR to approve this activity retrospectively – and may make it challenging for prospective providers to share anything of substance with trustees of DC schemes as part of the development phase. Given any authorisation application to TPR will need to have regard to a prospective provider’s expectations to build scale through commitment from DC schemes, it could be difficult to overcome the ‘chicken and egg’ dilemma here,” he says,

I had a conversation with TPR who tell me that the Code will be with us by Christmas. A Christmas present that most of the advisory community will find reasons to complain about because they like the idea of better pensions but hate the idea of doing the work to make them happen.

There is of course a good reason for that. While we moan about not getting enough by way of mandatory contributions (using auto-enrolment) we are happy to complain about getting an enhancement to CDC which the actuaries and the  Government assess as improving pensions by up to 60%.

That question is my question mark. Are those who manage our DC plans, our commercial plans – the ones we call master trusts, going to stop whingeing and use the very generous development plans offered them, to get on with it.

Or are they going to find more reasons to sit in DC and hope that CDC isn’t going to happen?

My advice to Corporate Advisers is that there are a lot of people outside the tent who are getting on talking with DWP and TPR and getting the finance together to put CDC together, not waiting till 2029 but using 2026 to test whole of life plans which can be launched at the end of next year.

But oh does this look a threat to the Corporate Advisers!

Mark Futcher (Barnett Waddingham) notes:

“It will be important to ensure that CDC does not inadvertently draw resource and regulatory focus away from further enhancing DC, which remains the system most savers rely on. CDC should complement, not crowd out, continued improvement in existing provision.”

Whether retirement CDC delivers a silver bullet in terms of better outcomes for members will only become clear once schemes are in place, suggesting much is resting on this consultation. 

Critchley (Aviva) says:

“The success of retirement-only CDC will depend on the attractiveness of the initial income, especially when compared to annuities, and how successfully schemes deliver on their promises.” 

Here is the backlash against the obvious enthusiasm people have for decent pensions;-  not indecent annuities or mysterious pots.

The attraction of annuities and drawdown to those who advise on and manage our retirement savers is only too obvious. You can watch it at DC award ceremonies, where the industry congratulates itself for earning so much money for itself.

We do not have to wait till 2029 to watch CDC succeed. We can get started today!

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Does Lord Gove think leaseholders will be freed? Harry finds out.

Posted on December 10, 2025 by henry tapper

Harry Scoffin succumbs to podcasting!

What am I doing , blogging a podcast? Well the rain is pooling on our roof  and coming through the ceiling both literally and actually, in the posh City of London. If we had a commonhold we would not have simply sold problems like this, but we have had to deal with delinquent freeholders for the 15 years I’ve been a a leaseholder and I’m a lucky fellow to have co-leaseholders who have taken action.

But even with all our bright minds, we still don’t get to speak to the freeholders who do nothing to ensure that the fabric of our building is maintained, despite charging us a ground rent and making sure we have no say in important decisions on matters such as insurance. I’m a Director of our leaseholders company and am empowered by Harry Scoffin, a young man on a mission.

Here he is with a man of a different generation , arguing for millions like me and my partner. Thanks Michael Gove, thanks Harry Scoffin, keep it going!

 

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A man and a woman making sense of investment for retirement

Posted on December 10, 2025 by henry tapper

I wish I’d put it as well as this man has

I’d wish I’d put it as well as this woman has

OPINION: Government must see pension investment as game changer for growth

UK businesses are facing many headwinds, but revitalising economic growth can help them overcome barriers to successful expansion. This will require higher long-term investment in infrastructure, housing, alternative energy, scale-up companies and modern technologies, without which corporate dynamism and growth will remain elusive.

Government policy seeks to increase spending on social benefits, the NHS and public services, to improve lives for many. However, paying for these, given the country’s fiscal deficit, has necessitated tax rises in the last two Budgets – and these will actually reduce economic activity and have been damaging to business confidence.

OPINION: Government must see pension investment as game changer for growth

Baroness Ros Altmann, former UK Pensions Minister

Of course, the impacts of the pandemic, higher energy costs and Brexit have hit public finances, so the Chancellor does not have unlimited spending powers. But tightening fiscal policy will not revive business prospects, especially as monetary policy is also relatively tight, because the Bank of England’s Quantitative Tightening program pushes up bond yields, which offsets reduced short-term interest rates.

British businesses want and need more long-term capital – preferably equity rather than just more debt. Government cannot provide sufficient funding but there is no need to despair. There is a potential solution waiting to be grasped, that could bring in billions of pounds of long-term capital, at no extra Exchequer cost.

Government could harness the power of pension assets as the game-changer that British businesses need to kick-start a new era of growth.

A radical change to the way the UK’s generous pension tax reliefs operate, could revive the flow of long-term investment capital. Recent figures show taxpayers spend around £80 billion a year on tax and National Insurance reliefs, to help people build private pensions. These are enormous sums, yet not a penny has to be invested here. And most of the money is used to buy overseas assets, which help boost other countries and not Britain.

If the Government were to require at least, say, 25% of all new pension contributions to be invested in UK assets, such as equities, real estate, infrastructure or small and unlisted companies, as a condition of receiving the taxpayer contribution to pensions, billions more could begin flowing into UK markets again.

This could help unwind the doom loop that has engulfed British equity markets. As UK pension funds have pulled out of equity markets in general and UK equities in particular, London Stock Markets have suffered lower trading volumes, reduced capital flows and higher corporate funding costs. Many good British companies have felt forced to buyback their own shares and increase dividends, instead of investing to expand or modernise their business operations. British companies have suffered a significant relative de-rating, higher corporate funding costs and many great businesses being snapped up on the cheap or moving abroad.

Instead of backing Britain, our pension investors have consistently reduced UK holdings, in an apparent vote of ‘no confidence’ in Britain. Over the past 20 years or so, most private pension funds have cut equity exposure from over 70% with most in UK markets, to below 20%, with only a small allocation to UK equities. Meanwhile, average bond exposure has increased from around 20% to over 70%.

The UK is a global outlier, as other major countries’ pension funds have significant overweightings in their home markets, including Australia and Japan with around 30% of their portfolios in domestic stocks.

By requiring at least a quarter of all new contributions to be invested in Britain, in exchange for the tax reliefs, the Government would be using existing expenditure to incentivise a nationally vital policy objective. Despite expressed concerns about fiduciary duty from many multi-national and passive fund management houses, there is clear justification for such a policy of incentivisation rather than mandation.

Pension funds will not be forced to increase UK exposure. If trustees or managers wish to invest more than 75% overseas, they can still do so, but they would not have the tax reliefs added to contributions. It is their choice, but of course it would also change the assessment of forecast future returns.

Most trustees or individuals would realise that the generous reliefs should more than outweigh any forecast UK underperformance over time. And the adoption of environmental, social and governance (ESG) restrictions on pension portfolios are not justified by short-term performance considerations, but are considered to protect against future problems. Equally, by reviving the regular flow of long-term pension assets into UK assets, trustees would be helping their members ultimately live in a better country in retirement.

Such reform could usher in a new dawn for British businesses, boosting our markets, investment and growth. This could be a win-win for the country, setting up a virtuous circle to reverse the doom loop of pension fund selling. A re-rating of UK assets can reduce corporate funding costs and attracting long-term investment capital from other investors.

What’s not to like?

Baroness Ros Altmann is an economic, investment and pensions policy adviser and former UK Pensions Minister

Ros Altmann
Steve Fine
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Back to the future; the return of the surplus; Stagecoach and Richard Jones

Posted on December 9, 2025 by henry tapper

HT looking a lot better in this picture

Richard Jones’ excellent explanation of the history of pension surplus kicked off a first rate discussion.  Have a look at the slides to get an idea of whether you want to devote up to an hour of the session.

Richard Jones is an old friend to many of us but if you don’t know him, you’ll feel like one of his cronies!

Here is the video

A large part of the conversation is about the impact of the Stagecoach/Aberdeen deal and what it may do to a market which has until recently been most dominated by insurance companies.

Read some fine comments from Derek Scott, who was for many years COT of Stagecoach and Peter Cameron-Brown who is to this day a COT of UKAS. They started their careers in these jobs back in the 1980s and offer a commentary on the DB world we had in the last century.

William McGrath and Richard may moan about the absence of data from those days , rightly so. There is much to say for transparency and there is much to come out on the rules of  distribution of surplus  from the Stagecoach Scheme.

We hope you enjoy it the debate, it is an historic document of the progress we are making. Yes videos as well as slide decks can be deemed documents!

I am sorry I made no contribution, other than to announce this “document” at the end. I spent a little time with my neurologist who was evaluating my little grey matter.

We agreed at the end of my consultation to listen to the discussion. He said that he understood about as much about pensions as I did about brain surgery. We agreed on that!

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Richard Jones at Pension PlayPen today? Yes please!

Posted on December 9, 2025 by henry tapper

How good it is to have someone I want to see , doing the promoting on his social feed!

and then see it again?

But you could stick with your local blog

The meeting will be all the more pertinent as it will happen of a week of the announcement of Stagecoach’s transfer of sponsorship of its Pension Scheme to Aberdeen Pension PlayPen Richard Jones

Back to the future! The return of DB Surpluses with Richard Jones

henrytapper.com

Paste this URL into your calendar if you prefer

https://teams.microsoft.com/l/meetup-join/19%3ameeting_Yzc2OTFmOTAtYjgxZC00YmZmLTllZTUtMDMyODhkOTU2MTBm%40thread.v2/0

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The embarrassing lottery of the default “pension” pathway.

Posted on December 9, 2025 by henry tapper

Peter Osthwaite of Dean Wetton Advisory

The analysis of what’s happening by default to people’s DC pots is from Peter Osthwaite and published in Professional Pensions.

The four pathways devised by the FCA to lead people to retirement take people to very different places. For some the place is delightful, to others an embarrassment to those who set the path up. The rest of this blog follows Peter Osthwaite’s examination of where one pathway takes you, it is the current default pension as it involves  doing  nothing.

Who were the winners and who the losers are not who you might think? Read through Peter’s article to find out who delivered and who screwed up!

The pathways were  introduced to provide structured, regulated options that were intended to simplify decision-making, helping retirees select an approach that best fits their intentions for accessing their pension funds.

By segmenting savers into four clear categories based on their expected use of their pension savings, the FCA aimed to address the lack of quality decumulation options and ensure that retirees have accessible, understandable choices for securing their financial future.

The four pathways are set out below to remind us of an initiative which will be overtaken by the Pension Schemes Bill.

 Pathway 1:

“I have no plans to touch my money in the next five years” – This pathway is for those who wish to keep their pension savings invested and are not planning to make any withdrawals in the short term.

Pathway 2:

“I plan to use my money to set up a guaranteed income (annuity) within the next five years”  This pathway is suitable for those who intend to purchase an annuity soon and want their money invested in a way that aligns with this goal.

  • Pathway 3:

“I plan to start taking my money as a long-term income within the next five years”  This pathway is for those planning to draw down their pension savings gradually to provide a regular income over the long term.

  • Pathway 4:

“I plan to take out all my money within the next five years” – This pathway is aimed at those who intend to withdraw all their pension savings within a short period.

Of these, Pathway 3 will become the default decumulation fund for those in defined contribution plans reaching their retirement age. But it is not today.

The current “default”  is Pathway 1 – it is the path that people are following if they make no decision and see their pension pots just rolling up. What follows is Peter Osthwaite’s analysis of how people on the Pathway 1 roll up are getting on and where they’re ending up

Pathway 1 performance

In this article we focus on the first pathway, which a saver should choose if they identify with the phrase

“I have no plans to touch my money in the next five years”.

The performance of Pathway 1 products from various providers has been analysed below. We looked at each strategy for a member that is 70 years old today (so 65 five years ago) and tracked the monthly returns of each strategy using the actual experienced returns of the underlying funds up to the end of quarter three 2025 (though noting that some of these funds may not have been used as a Pathway 1 product for the full five years).

We assumed a starting pot size of £500,000 and that members neither contributed to nor made any withdrawals from their pot during this five year period. The following chart tracks the change in pot size over the five year period.

Changes in pot value over the last five years
Source: DWA

There is an over £277,000 difference in outcome between the strongest performer (Utmost) and the lowest performer (Aegon). Members in Utmost would have seen an over 50% boost to their pot size compared to members in Aegon. This monumental difference appears to predominantly come down to a combination of equity exposure and government bond exposure.

For Pathway 1 Utmost invests in the Utmost Multi-Asset Growth fund, which targets a 60-80% equity allocation, and at time of writing in November 2025 was sitting at just over 70% invested in equities, with around 5% in UK government bonds and the rest in other fixed income products.

In contrast the September 2025 factsheet for Aegon Target Plan Growth Pathway has an equity content of around 30%, with just under 28% invested in UK gilts and around 22% invested in international government bonds.

Over the last five years, despite some upsets, the dominant investment themes have been ones of large cap equity growth, with particular success for large US tech stocks. Within this period, 2022 was one of the worst years for financial markets on record with rapidly rising interest rates hammering fixed income, with UK government bonds being one of the worst affected asset classes. However many would say the last five years have been unusual for markets, and that as volatility returns diversification may be more beneficial.

What is an appropriate level of risk for Pathway 1 investment?

All this raises the question, what is an appropriate level of risk for a five-year investment and therefore what kind of product best suits Pathway 1?

One problem is defining the parameters of Pathway 1. If a member invests in Pathway 1, one year later should we still assume that they have no plans to touch their money for the next five years or should we assume that they now may only have four years left before they touch their money? This problem can be even more pronounced in the other Pathways but still bares considering for Pathway 1. None of the considered Pathway 1 options implement any kind of lifestyling which implies that the common belief is that until such time as a member chooses an option there are always at least five years before they intend to access their pot.

A five-plus year timeframe would typically be seen as a medium-term horizon. It is a timeframe over which it is reasonable to assume that a growth like portfolio would see positive returns. That there is enough time to recover from any near term market events. This would tend to suggest a slightly riskier portfolio than one might expect for a retiree.

The counter question, however, is how reliable do we believe the saver’s own assessment of their needs is? Many people do not know when they are going to begin accessing their retirement savings until very shortly before they retire or they need the money. Is it the responsibility of the provider to ensure that a saver who suddenly realises their timeframe is shorter than expected is not taking on too much risk to accommodate this?

If the products are to be workable it makes sense that the provider must be able to rely on a member’s assessment of when they will access the money, any other outcome risks causing detriment to members who have a sufficiently long investment timeframe. Ultimately the solution probably lies in better saver education, and a wider array of clearly defined options to better target specific outcomes.

Pete Osthwaite is head of DC trustee solutions & ESG research at Dean Wetton Advisory

 

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“No growth <—> No pensions”. John Hamilton; COT of Stagecoach Pensions

Posted on December 9, 2025 by henry tapper

A statement from John Hamilton , Pension Scheme Chair at Stagecoach. A statement to a wider audience than the “pensions industry”

This is the text of the document that John is socialising.

Beyond the pension industry

There has been a call from Bryn Davies (Lord Davies of Brixton) on this blog for greater detail of what improvements the members will get.

I hope that the unions will delight in the details starting with this statement from the Stagecoach Trustees.  I hope they will see an opportunity to press for further deals that benefit working people.

I hope that “members” will in time include staff looking forward to pensions from DC and CDC and that those pensions will be improved by the actions of Trustees adopting a positive position on the growth of pensions we have seen here.

No growth <—> No pensions

I take this formula from a recent comment by John Hamilton

In a week when the Pensions Regulator has issued a statement on the need for investment,  the formula sounds a cry for change.

This message must get beyond the pension industry and I hope that the unions , lead by Lord Davies and others like John Hamilton , will bring pressure to bear, to keep the message ringing around Whitehall and well beyond!

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TPR probes barriers to investment – a hat-trick of wins in a week.

Posted on December 9, 2025 by henry tapper

Nausicaa Delfas, TPR CEO

I am pleased that TPR is changing its stance. The principles it has laid down are risk based but overly so . Trustees have complained that they live under a regime where they can be considered wreck less by TPR, rendering them subject to criminal proceedings from which prison can follow. This is a positive statement,

I am pleased to see two other pieces of  good work from TPR last week. The first I have written about, the transfer of Stagecoach to Aberdeen as sponsor of Stagecoach’s 22,000 DB pension members.  The second is the ensuring of pension benefits of Northern Foods Pension Scheme’s 13,000 members. The are better protected as a result of TPR’s enforcement.

It is clear that a new TPR is emerging from the distressing position it took towards Trustee’s looking to grow funds alongside the firmness it has shown with Northern Foods.

An encouragement of investment along with an unflinching insistence on recovering from deficits (where this can be done) shows a Pensions Regulator we could be proud of.

Here is the Regulator’s statement which I hope represents a new kind of regulation to match the new legislation which is happily passed through the Commons last week

TPR probes barriers to investment in private markets and infrastructure that could deliver better returns for savers

Monday 8 December 2025

The Pensions Regulator (TPR) has launched an initiative to explore the approach of defined contribution (DC) and defined benefit (DB) pension schemes to investing in growth assets that could boost returns for savers over the long term, and to better understand the barriers to doing so.

Through the voluntary Mansion House Accord, 17 workplace pension providers have signalled their intent to invest more in private markets by 2030, including in the UK. The announcement in October of the Sterling 20 partnership between 20 of the UK’s largest pension funds and insurers has continued to build on that momentum. TPR published private markets guidance last year to help trustees to improve outcomes for savers by properly considering the full range of options available.

In the current phase of its work, TPR is using its sector insights to understand the range of market opportunities and investment vehicles available to pension schemes, their limitations, barriers and enablers, with an emphasis on UK investment opportunities.

The government’s industrial strategy presents opportunities for pension schemes to invest over the longer term in growth sectors, such as science and technology. By providing insights from across the market, TPR wants to help to create the conditions for schemes to consider investing in a pipeline of assets with long-term benefits for pension savers.

TPR is focusing on DC and DB schemes, with material scale, which may be considering or have the potential to make investments in this area.

TPR plans to complete this engagement by the end of 2025. TPR will share findings with Government and will publish a market oversight report, next year, so that trustees and expert advisers can benefit from the insights that TPR has gained.

Chief Executive Nausicaa Delfas said:

“TPR is uniquely placed to engage directly with DC and DB schemes to better understand their approach to investing in private markets and infrastructure, as well as the current challenges and barriers they face. We hope our research will provide insight to help trustees consider investment in diverse assets to achieve better returns for savers.”

Through TPR’s ongoing engagement with master trusts and other DC schemes, we see indications that the market is already responding to the Mansion House commitments with trustees considering more diversified investment strategies.

Executive Director of Market Oversight Julian Lyne added:

“In the coming months, we plan to ramp up our work to encourage high standards of trusteeship and scheme governance. We expect trustees to acquire the skills, capabilities and access to professional advice to consider investing in diversified portfolios.

“Where schemes fall short, we will be asking trustees to consider whether it would be in savers’ interests to consolidate into larger vehicles with greater investment capabilities.”

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Pension Bee’s campaigned for “pot transfers” since the days of Robin Hood

Posted on December 9, 2025 by henry tapper

Pension Bee’s original idea

Pension Bee have for nearly 10 years fought the good fight for easier , cheaper and quicker pension pot transfers. Here is the latest version of what started life as the Robin Hood index!

Ok – here it is!

Broken beyond excuse: PensionBee calls on Government to end pension transfer gridlock

Steven Kennedy

by Steven Kennedy , Head of PR

Dec 2025

PensionBee, a leader in the consumer retirement market, has today launched its third report, Faster, Fairer, Digital: The Pension Transfer Reset, calling for urgent Government and regulatory action to modernise the UK’s outdated pension transfer system.

The new report exposes a system that continues to fail savers who want to engage with their retirement savings, with some pension transfers still routinely taking months – or even years – to complete. Despite examples of excellent practice on the part of some providers, others continue to drag their feet, remaining reliant on paper forms and manual processes that create unnecessary friction and using ‘sludge’ tactics to delay transfers.

The result is confusion, frustration and anxiety for consumers trying to move their own money.

Building on PensionBee’s ongoing 10-Day Pension Switch Guarantee campaign and earlier reports – A Switch in Time (May 2025) and Ending Pension Purgatory (July 2025) – the latest publication moves beyond diagnosis to a clear call for policy action.

It outlines five practical recommendations to create a faster, fairer system and warns that without decisive intervention, progress will remain inconsistent and uneven.

Among them, is the call for a 10-day Pension Switch Guarantee, which should apply in all but the most complex cases. Existing legislation urgently requires reform to remove structural barriers to efficient transfers and modernise the system.

Five key reforms for a fairer, faster system

The report urges the Government and regulators to:

  • Mandate digital transfers across all pension schemes, with an immediate focus on trust-based schemes regulated by The Pensions Regulator (TPR).
  • Introduce a Pension Switch Guarantee to ensure the majority of defined contribution pension transfers are completed within ten working days.
  • Require providers to publish performance data, giving consumers transparency and the ability to compare providers, holding providers to account.
  • Fix transfer scams legislation by reforming the current Amber and Red Flag system to prevent misuse as a pretext for delay.
  • Reduce the statutory six-month transfer deadline, which has not been updated for over thirty years and is no longer fit for a digital era.

A fragmented system holding back progress

PensionBee’s analysis highlights that having two regulators – the Financial Conduct Authority (FCA) and The Pensions Regulator (TPR) – has led to a confusing two-tier system for consumers.

While FCA-regulated providers routinely complete digital transfers in days, many trust-based schemes overseen by TPR are lagging behind.

This fragmentation, combined with legacy IT systems and a lack of enforceable service standards, has created a lottery for savers.

The report highlights that despite widespread acknowledgement that the pension transfer system requires an overhaul, the industry has proven incapable of raising its own standards to a level that would produce a materially better experience for savers.

It concludes that whilst voluntary collaboration has been an important step, only government and regulatory leadership can deliver consistent outcomes across the market.

Growing momentum for reform

More than 6,500 people have already signed PensionBee’s public petition for a 10-Day Pension Switch Guarantee, with numbers rising ahead of the January 2026 deadline.

With the Pensions Dashboard rollout and upcoming inheritance tax changes expected to trigger a surge in pension consolidations, PensionBee warns that millions more savers could soon face the frustration of avoidable transfer delays unless action is taken now.

A clear call for Government and Regulator leadership

PensionBee’s report finds that voluntary initiatives, such as STAR, while helpful, have not achieved universal adoption or enforceable standards.

Instead, the report calls for the Department for Work and Pensions (DWP), the FCA and TPR to act together to deliver a digital-first pensions system with clear rights for consumers and accountability for pension providers.

Lisa Picardo, Chief Business Officer UK at PensionBee, said:

“Britain’s pension transfer system is broken, but it’s capable of being fixed. People quite rightly expect their pensions to work like every other part of their financial life – to be simple, efficient and digital.

If you can move money between banks in seconds, there’s no excuse for pensions taking months.

In 2025, it’s unacceptable that savers are still waiting months – sometimes even years – just to move their own money. The technology to deliver fast, secure digital transfers already exists and is proven to work.

What’s missing is the consistency, accountability and the will to make it universal.

It’s now time for the Government and regulators to step in, set enforceable standards, and hold providers to account.

Savers deserve a system that’s fast, fair and trustworthy – not one that traps them in endless paperwork and delay.”

That pile of paper still looks pretty daunting!

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