CP26/1: The Value for Money Framework: Response to consultation, further consultation and discussion paper

Read CP26/1 (PDF)

Why we are consulting 

We are proposing revisions to make the way arrangements are assessed and compared more objective and robust. We are also responding to feedback and refining the data required. 

The main changes proposed since consultation CP24/16 are:

• The introduction of forward-looking metrics to be considered alongside backward-looking metrics in assessments.
• Fewer cost and backward-looking investment performance metrics, focused on key metrics.
• Streamlined service quality metrics to allow further engagement with industry on others.
• Comparisons of value against a commercial market comparator group rather than 3 other arrangements.
• A four-point rating system rather than three, to allow identification of top performers.

Who this is for

We encourage firms operating contract-based workplace pensions, their IGCs and GAAs, and the trustees of trust-based schemes to respond to this consultation. We welcome feedback from:

• firms operating contract-based workplace pensions
• IGCs and GAAs
• trustees and sponsors of trust-based schemes  
• DC pension scheme savers and beneficiaries  
• pension scheme service providers, other industry bodies and professionals
• employers
• civil society organisations
• consumer organisations / representatives with an interest in pensions capability / financial capability
• pensions administrators
• any other interested stakeholders

Next Steps

Online response form

We are asking respondents to reply to the FCA and the Pensions Regulator (TPR), who will share responses with the Department for Work and Pensions (DWP).

Email: [email protected] and [email protected] – please send to both addresses.

Or in writing to either:

VFM Framework
The Pensions Regulator
Telecom House
125-135 Preston Road
Brighton BN1 6AF.

VFM Policy Team
Financial Conduct Authority
12 Endeavour Square 
London E20 1JN.

Background

The Government is progressing the Pension Schemes Bill 2025 to create new rules for certain trust-based pension schemes with defined contribution benefits. Consultations on draft regulations and supporting guidance will follow, led by DWP and TPR. At the same time, rules for contract-based schemes are being developed, with a parallel consultation planned. We are currently working towards 2028 for the first VFM assessments to be required.