Improving member outcomes: what next for Defined Contribution pension schemes?

6 minute read
01 October 2020

The Department for Work and Pensions (DWP) has published its response to the 2019 consultation "Investment Innovation and Future Consolidation", together with a new consultation on improving outcomes for members of defined contribution (DC) pension schemes.

The new consultation, entitled "Improving outcomes for members of defined contribution pension schemes", ("2020 Consultation"), sets out measures aimed at encouraging DC pension schemes to invest in a more diverse range of long-term assets (including so-called "illiquid" investments, such as venture capital and green infrastructure) and also proposals to require the consolidation of smaller DC pension schemes into larger ones.

Here, we consider the Government's latest proposals and what they mean for DC occupational pension schemes.

Key action points

1. New DC consultation published

On 11 September 2020, the DWP published its response to its February 2019 consultation "Investment, Innovation and Future Consolidation", together with a further consultation on improving member outcomes for DC schemes.

2. Diversification of assets

A key focus of the new consultation is to encourage trustees of DC pension schemes to invest in a more diverse range of long-term assets.

3. DC consolidation still firmly on the Government's agenda

The new consultation also focuses on DC consolidation, which is still clearly viewed by the Government as being key to promoting good governance and value for members.

4. Clarification to be provided on costs and charges information

The new consultation proposes updating the statutory guidance to increase clarity for trustees on minimum expectations on the production and publication of costs and charges information for the purposes of chair's statements.


In February 2019, the Government published its consultation "Investment Innovation and Future Consolidation". That consultation asked for views on the Government's proposals to encourage DC pension schemes to invest more widely, particularly in start-up companies, housing projects and green energy. The consultation also suggested that small DC schemes be required to assess every three years whether they should consolidate into a larger scheme in order to ensure better member outcomes.

The 2020 consultation

Taking into account responses received to the February 2019 consultation, the Government is now consulting on further measures to encourage more diversified investment and improve DC scheme governance.

Diversification, performance fees and the default fund charge cap

The 2020 Consultation proposes a change to the way compliance with the default fund charge cap is measured for performance fees to give trustees greater flexibility in their investment decisions. The aim of the change is to encourage trustees to diversify their investments and, in particular, to facilitate investment in illiquid assets.


Trustees of smaller DC schemes (that is, DC or hybrid schemes with assets of less than £100 million and that have been operating for at least three years, as at the relevant date) will be required to assess key elements of the value achieved by their scheme (including costs and charges, net investment returns and other elements of governance and administration) and to report on the outcome of that assessment in their chair's statement and scheme return. The 2020 Consultation refers to this as a "new and more holistic value for members' assessment".

Where this assessment shows that members would achieve better value in a larger scheme, trustees are expected to initiate wind up and consolidate. However, trustees will not need to consolidate and can instead try to make improvements where:

  • they are "realistically confident" that the required improvements can be made; and/or
  • the wind up and exit costs may exceed the costs of making improvements; and/or
  • there are "valuable guarantees" that would be lost on consolidation.

Trustees will be required to report their proposed approach to the Pensions Regulator. Should the trustees then fail in their attempts to improve, they will then be expected to wind up and consolidate the members into a scheme that offers better value.

Interestingly, in the 2019 consultation, the Government proposed that the requirements to assess and consolidate apply to schemes with less than £10 million in money purchase assets. This threshold has now increased significantly to £100 million of assets. In addition, the new value for members assessment must be conducted annually, rather than every three years as was originally proposed.

Other changes to legislation and statutory guidance

Other proposed changes to legislation and statutory guidance include:

  • clarification regarding the minimum expectations on both the production and publication of costs and charges information for the purposes of chair's statements;
  • extending the requirement to produce a default Statement of Investment Principles (SIP) to "with profits" schemes;
  • excluding wholly insured schemes from some of the SIP requirements; and
  • extending the existing costs disclosure requirements to those funds that are no longer available for members to choose.

What next?

The consultation closes on 30 October 2020 and the amendments to bring in the changes referred to above are to come into effect on 5 October 2021.

DC schemes and improving outcomes for members of those schemes clearly continue to be a priority for the DWP. If these changes are introduced, there will be yet more responsibility placed on DC pension scheme trustees. The question remains as to whether increased regulation will help achieve the desired aim of improving member outcomes.

We intend to respond to this consultation.If you have any views that you would like us to include in our response, please contact Joanne or Stephanie.

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