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1. 2 Sep 2025·Parliament·Mark Garnier

   Pension Schemes Bill (Second sitting)

   Q There is potential for surpluses to be paid back into the community. Is that not a good alternative for that type of more social investment as opposed to non-commercial investments? Councillor Phillips: We anticipate that the latest round of valuations will show a very good surplus for all the pensions. That is credit to the investments that have been made to date. That does pose some issues as to what you do with those surpluses, but we live in a very volatile situation, and circumstances can change. You have to be careful, because if you reduce contribution rates considerably, that is a great benefit at this moment in time, but if you then turn around and start to increase them again, that can be very difficult for all employers to deal with, including local government.

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2. 2 Sep 2025·Parliament·Mark Garnier

   Pension Schemes Bill (Second sitting)

   Q That is very helpful. Robert, would you like to add anything? Robert McInroy: Yes, on the last point about surpluses. I am a fund actuary. We are working through the 2025 valuations, and it is pleasing to see improvements in funding levels across the LGPS. We think that that, in turn, can mean lower contribution rates, particularly for councils—something in the region of 3% to 6% of pay, so that is positive. It is important to realise that the success of the current scheme has perhaps not been picked up in some of the language and assumptions built into the reforms that have been put forward.

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3. 2 Sep 2025·Parliament·Mark Garnier

   Pension Schemes Bill (Second sitting)

   Q Would you suggest a higher hurdle for valuations in terms of surplus distribution? Robert McInroy: That has been discussed on a fund-by-fund basis—whether the funding target should be increased from something like 100% to 120%, for example. That has been actively discussed.

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4. 2 Sep 2025·Parliament·Mark Garnier

   Pension Schemes Bill (Second sitting)

   Q Would you support that? Robert McInroy: I support looking at the range of options, which includes reducing employer contributions and flexing investment strategy, including for some of the areas that we have talked about and will be talking about, that could be available to the LGPS in terms of investments.

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5. 2 Sep 2025·Parliament·Mark Garnier

   Pension Schemes Bill (Second sitting)

   That is very helpful; thank you.

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6. 2 Sep 2025·Parliament·Mark Garnier

   Pension Schemes Bill (Second sitting)

   Q There has been a lot of talk about mandation, which you will be well aware of. Over the time that I have been researching it, over the last few months, we have had pretty much exclusively commentary that it is not a very good thing. Tell me that that is wrong. Why is it possibly a good thing? Helen Forrest Hall: I would love to say that. I start by saying that the PMI supports the principle that larger pension funds are likely to lead to better outcomes for members. A great and growing weight of evidence, and obviously an awful lot of international experience, shows that they provide greater economies of scale and greater opportunities to invest in a broader range of assets. Unfortunately, we believe that the reserve power sets a dangerous precedent of political interference with a trustee’s fiduciary duty. The considerations of each individual pension scheme are a matter for the trustees, taking into account their members’ experience and what will drive the best outcomes for those members. Obviously, significant progress has already been made in terms of pension schemes demonstrating their desire to meet the Government’s eagerness for them to invest in a broader range of assets, and the consolidation elements of the Bill should help with that. But I think that the reserve power provision runs a serious risk of cutting across that well-founded fiduciary duty, as well as creating all sorts of disruption to long-term investment planning—another thing that pension schemes are well set up to do—and creating market distortion. Sophia Singleton: We are very much aligned with the Government’s objective around investing in these assets. We believe that they can deliver and, as Helen has said, the industry has already made quite a strong move towards investing in them. We are going to get there, and it is really about not forcing that to happen too quickly. Schemes need to deploy capital when the opportunities arise and when the right time is, otherwise we risk distorting the market. That is a real concern, because it could deliver poor outcomes for savers. I am sorry we cannot give you a different answer, but we have three concerns about the mandation. Who is legally accountable if there is underperformance? Underperformance is possible. Is it the Government? Is it trustees? How will it affect the markets? How will it affect public trust? At a time when people need to save more into their pensions, they will worry that their pension scheme is no longer investing for returns as a priority.

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7. 2 Sep 2025·Parliament·Mark Garnier

   Pension Schemes Bill (Second sitting)

   Q Helen, can I pick up on your comment that you have to make long-term decisions? These reserve powers have a sunset clause that will apply in 2035. Presumably, if you are making an investment decision, you have to take that into account. An investment decision could be expected to pay out in 2040, and in making that decision you would have to take into account the possibility, remote though it may be, that your investment objectives may be forced to change between now and 2035. How will that affect the performance of a fund, even if the power is never used? Helen Forrest Hall: That is the problem with a reserve power. It does not have to be used to influence the decisions that trustees are making about their investment strategies, because they have to consider the instances—and there is not an awful lot of clarity in the Bill about what those instances would be—in which this power might be used. They might suddenly find their long-term, well-considered investment strategy outwith Government legislation. That is a dangerous place to be. Pension schemes, quite rightly, are doing their job when they are thinking about their members and their beneficiaries, and making long-term investment decisions. They have the capacity and the joy of being able to do so, but that means that they have to think about those kind of time horizons. That means that a reserve power with a sunset clause with that kind of short-term time horizon will start impacting decisions that people are making at the moment.

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8. 2 Sep 2025·Parliament·Mark Garnier

   Pension Schemes Bill (Second sitting)

   Q So if this clause is passed, we could potentially see a drop-off in the performance of pension funds? Helen Forrest Hall: I am not sure that we would draw a direct correlation, but the point is that it will start to influence investment decisions. Those may be good decisions, or not, and they may be decisions that trustees would have made anyway; the challenge is that the reserve power exists, a good trustee and their legal advisers will be taking account of that at the moment. Sophia Singleton: We believe that the threat—just the threat—of this power is the worst of all worlds, in a sense, because the lack of clarity about what trustees should do and take into account when investing for the long term makes it very difficult for them to carry out their fiduciary duties.

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9. 2 Sep 2025·Parliament·Mark Garnier

   Pension Schemes Bill (Second sitting)

   Q It has been suggested to me that the mere fact that this reserve power is in existence may subconsciously encourage funds to invest in the UK, and that therefore they can naturally find 5% investment into the UK and infrastructure, or maybe even more. Do you think that is a valid point? Sophia Singleton: What I would say is that we are already moving in that direction. If you look back a few years ago, it was very difficult operationally for defined contribution schemes to invest in those types of assets. If you look at things now, both on the supply side and the demand side we see factors that are really supporting investment in those assets. On the demand side, the new value for money framework really incentivised investment into private market assets because of the risk-adjusted metrics included within the framework, and the work that the industry and regulators have done to take away the operational barriers that existed. On the supply side, the Government have committed to help to create that pipeline of investments. Publishing the pipeline that is coming up is very helpful, because people can plan how to employ their capital, and having the British Growth Fund and so on to invest in alongside the private sector is also helpful. We are already seeing it happen: we are seeing funds recruiting investment experts to help to manage those assets, so they are already gearing up and skilling up to do this, and we are seeing fund managers releasing private market funds suitable for DC schemes on a regular basis. We do due diligence on those funds, and there are more and more that we have to look at. So it is happening.

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10. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q It is happening; that is very good, and it is good to hear that there is a pipeline being developed. It is certainly something that has been talked about for a number of years. When I was the investment Minister back in 2017-18, we were very keen to get foreign direct investment coming in to the UK, so there was the Office for Investment in No. 10 doing all that stuff. That begs the question that, as the Government at any time is trying to attract foreign direct investment into the UK, not least to try to sort out the current account deficit, you as pension fund managers will find yourselves in competition with, hopefully, foreign investors coming into the UK. What is the hierarchy of offer? Do you think UK pension funds should be offered exciting investment opportunities before foreign direct investors? Sophia Singleton: I do not think we should be interfering with the market; I think it needs to be a free market and, as trustees of pension schemes, we need to be exercising fiduciary duty to choose the right investments for our members and to give the returns.

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11. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    But you would rather see the opportunities first? Sophia Singleton: Absolutely—we would love to see the opportunities first. Helen Forrest Hall: The other dynamic there is that international pension funds, for example, are often looking to invest in the UK for reasons different from the reasons UK pension funds might want to invest. For them, it is often a smaller part of their portfolio, and part of their own need to diversify where their assets are, in order to manage their own volatility risks. There has been a history of going after the same investments, and unfortunately that is the market and that is healthy competition. One of the challenges and one of the market distortions we see with things such as the reserve power is that you will have the same group of people fighting over what, for a short period of time, is inevitably going to be a short pipeline. That will have an impact on things such as the value for money that you are getting for those investments.

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12. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    That is very helpful; thank you very much.

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13. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q Ian, can I start with you? One of the problems with auto-enrolment is where individuals move from one job to the next, not with a small pot under £1,000 but with a slightly bigger pot that is none the less still administratively tricky. Do you think that the Bill sufficiently tackles that problem? Ian Cornelius: I do not think that the Bill particularly focuses on that problem, but the question is whether it is a problem. The pensions dashboard will help to provide more visibility of where people’s money is and help them to manage that more effectively. I think it is right to focus on small pots, because they are inefficient. It is much harder for consumers to track lots of small pots, and it is driving costs in the industry, so I think that that is the right initial focus.

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14. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q One of the original ideas of the last Government was to have a lifetime pot, whereby an employee would pay into a fund, but it was deemed by the industry to be quite difficult to administer, because as an employer you would have to be dipping bits into different pots. What was put up as an alternative was a magnetic pot, whereby an individual would be able to move their money from one pot to the other. Each time they changed jobs, that pot would be picked up from employer A and moved to employer B’s pot. Do you think that is a sensible alternative? Ian Cornelius: Customers—members—can already do that if they choose to.

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15. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q Do they know that they can do that? Somebody who is changing jobs quite a lot would not necessarily be the sort of person who is making strategic decisions about their retirement. Ian Cornelius: I think that is right. It probably goes back to dashboards. They are key to helping to increase visibility. That will get people thinking about the choices they can make, how they want to manage their pension and how they can consolidate their pensions. That will drive that type of activity naturally. At NEST, we have always had one pot per member to make it as easy as possible for our members. Ultimately, it is about member choice.

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16. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q Yes, that is kind of helpful. Patrick, could I turn to you? We met and had a very interesting chat. One thing we discussed was the scale of the funds. There is a requirement in the Bill that funds such as yours will need to be valued at £25 billion by 2035. One thing we discussed at the time was whether that creates a barrier to entry for new asset managers, and a lack of competition among asset managers in order to provide the best value for those funds. Would you share some of your thoughts about the £25 billion minimum size? Patrick Heath-Lay: Yes, of course. We have conducted research. Toby Nangle did some research for us in 2025, and WPI Economics has also looked at the issue of whether scale drives better economies. Generally, aside from all the international comparisons from Canada and Australia, it is proven that scale will drive better economies. You can leverage scale to drive a more efficient administration. If you are asset owners like these two organisations, we get to choose where we invest the money, which managers we use, who will come with the best solutions and who has the best routes and access to market to allow us to invest in a way that benefits and shares the benefit of that investment with the end saver, which for us as an organisation is the sole focus. I believe that scale, utilised in the right way, does deliver those efficiencies, but this is where the package in the Bill, and particularly a key element like value for money, is critical to establishing that as this market evolves. You want to be reassured that the investment activity at that scale is delivering increasing value for members, which is really the sole purpose of driving that scale. From our own experience and the research that we have done, it is a proven model, but that scale needs to be harnessed in the right way.

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17. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q I completely agree: I think it is absolutely right that the more money you have, the more negotiating power you have and the more you can diversify risk and all the rest of it. But part of what I am worried about is this: how is anybody going to prove to the regulator that they will have £25 billion of assets under management by 2035? Surely that is an incredibly difficult thing to prove. Patrick Heath-Lay: I do not want to be flippant in my response, but our scale already means that we are over that limit, so I have not really put too much thought into how they will do it. I believe that there is enough, within the business plans of entities that might be affected, to be able to make some reasonable assumptions as to what ongoing contributions will be coming through the door and how they will respond to some of the opportunities that may arise in this market over the next few years, from organisations that are choosing to move because of the extent of change that is coming. I emphasise that I still think that the package of measures and that scale test is the right thing to instil that movement, because I think savers will be better off, provided that it is harnessed in the right way. That is why I come back to this: value for money is the proof point, and we need to make sure that we centre on that as an industry. Being able to evaluate how these changes have created a more competitive market in key areas going forward is really quite important.

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18. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q I want to ask about the value for money framework. There seem to be a lot of fans of the value for money framework. Are Phoenix as enthusiastic about it as everyone else seems to be, if that is not too loaded a question? Tim Fassam: The short answer is yes, we are big fans of the value for money framework, but it is worth thinking about why that is. When we are looking at why we have not had the investment that we would necessarily expect, and that we see in other similar countries—so, exposure to private markets and exposure to productive assets—we think there are roughly three groups of reasons. Some are cultural and have been helped by things such as the accord and the compact. Some are regulatory, and that will be a major topic of conversation in this Committee. But some are market, and the market challenges are really around who is the buyer of automatic enrolment pensions. That is usually the employer. Historically, we have seen most employers focus on the charge, and the charge alone. That means we are now seeing charges well below the price charge cap for automatic enrolment, which is a good thing for consumers, but it is at such a low level that it is very hard to offer more enhanced investment solutions, so that means they tend to be invested in more passive investments and trackers. The value for money framework is important because it should have an impact on those purchasers, making it easier for them to see a more holistic view of the value that they are getting from the pension that is being offered to them, in terms of investment, service and a wider range of metrics. We are not sure it is perfect, as currently developed, but it is certainly in the right direction.

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19. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q There was an interesting intervention yesterday from the Reform party about local government pensions. I know that is not necessarily part of what we are talking about now, but they made the point that 50 basis points is way too much to charge for assets under management and that it should be 10 basis points instead. You raise exactly that point, which is that it is not about how much you are being charged, but about a combination of that and the performance and how much you are growing. I am 100% behind that particular point, because it makes a huge amount of sense, but one of the things that slightly bothers me is about the metric data. It looked at the quality of service provided to members, which is a nice thing to have—it is about whether you are looked after properly—but it is a marketing type of thing. Slightly more important are the investment performance and the cost, and also the asset classes that the scheme or arrangement invests in. Where I begin to get slightly confused is that it then switches to member satisfaction surveys. I am curious as to what the member is. You raised the very good point that the customer is the business, but that is not the same as the member. Who is being asked whether they are investing in the right assets? That is quite a technical question by the time you start looking all of this. Can you see that there are anomalies and Gordian knots within this? Tim Fassam: There is certainly a lot of detail to be worked through. That will include understanding the impact of all these factors. For example, investment return will be an incredibly important part of the value-for-money framework. It is very hard to do forward-looking investment return analysis, but if you do backward-looking, you cement the best of what we have today. The premise of the Bill is that we want to see a different investment pattern going forward. It will be very hard to, say, model a higher allocation to private markets in a forward-looking metric unless we have some creative thinking. Getting those investment metrics right is absolutely critical. Service does matter to customers in terms of how easy it is to deal with and how much support they are getting to make good investment decisions. That will have a significant impact. When you combine it with things like the potential for targeted support, that could make a very significant difference in terms of the outcomes that the consumers get. We always think of the end customer being the individual. We have a close and important working relationship with the employer, and they are often working with employee benefit consultants to choose their scheme, but the most important stakeholder in all of this is the end user. We want them to get the best possible result to help them prepare for retirement.

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20. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q I have one final question. Various clauses look at the asset manager and the trustees effectively marking their own homework on this. There are consequences of an intermediate rating, consequences of a “not delivering” rating and various other issues. Is that the best way of doing it? To a certain extent, the managers and the trustees have a vested interest in doing well. Tim Fassam: We are certainly concerned about the intermediate rating and the risk that that could cause a cliff edge if it means that, to get an intermediate rating, you are effectively closed for new business and potentially existing new joiners for a new firm. We think an intermediate rating that aligns with delivering value, but with a warning light that gives the firm a couple of years to get back into high value for money, will stop the perverse consequences. What I mean by perverse consequences is that if the cost of underperformance is significantly higher than the benefit of outperformance, you will see everyone herding in the middle. That will mean that you may well get a better outcome than today, but you will not get the competitive pressure to be the best of the best, which I think will see the better outcome in the longer term.

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21. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q Very quickly, if you get an intermediate rating, is it published? Tim Fassam: Your value for money rating will be published.

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22. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q So you could run into the same problems that we saw recently where the Financial Ombudsman Service was publishing who has been under investigation, which caused problems. That has now been changed, but we could be entering into that same problem. Tim Fassam: If you see very strong market or regulatory consequences for hitting an intermediate rating, the focus will be on not being intermediate rather than on being the best that you can be. We would like to see a focus on delivering the best value for money that you can.

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23. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q The Bill provides for surplus extraction from funds. Do you see that as a good or a bad thing? Morten Nilsson: I see it as a good thing. I think it will change the pension industry quite a bit as a positive innovation. Closed DB schemes, which we focus on, might be seen more as an asset for sponsors, rather than a liability that they would like to get rid of as quickly as possible. I think that it will create quite a lot of innovation, and a lot of good things will come out of that.

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24. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q For defined-benefit pension funds? Morten Nilsson: Yes.

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25. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q One of the questions around that is what drives a removal. We heard from previous witnesses that if a host employer puts in more money than is necessary, it seems perfectly reasonable for them to get some of that back. In some cases, that money could be used for investment in plant and machinery to expand the employer, but at the other end of the scale it could be used for share buy-backs to enhance the share price of the employer. Do you think it matters what happens to the money that is being withdrawn from these pension schemes, or should that be up to the host company? Morten Nilsson: I see it pretty much as you described. The main duty of the sponsors and the trustees is to ensure that there is enough money in the scheme to pay the benefits that were promised to members. If there are excess funds, it is reasonable that they can be invested back into the economy. In May, we surveyed 100 finance directors who are responsible for schemes with over £500 million of assets: 93% of them said that they would want to access the surplus, 49% said they would reinvest it in their local business, in the UK, to create jobs and do other good things, 44% said they would consider sharing it with members, 42% said they would invest it in their global operations, 40% said they would pay it back to shareholders, and 33% would invest it in DC. That is quite a wide range of uses. I think some of it will be paid back to shareholders, which may be local or abroad, but I expect a lot of it would be invested back into the UK economy in one way or another.

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26. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q Michelle, you run the compensation scheme. Do you see any risk in surplus extraction? I know that by definition, it is surplus and therefore you should be able to take it out, but at the moment, a lot of funds are in surplus. We went through a period of low interest rates, where it was a bit tricky, but now interest rates have gone up, and suddenly those funds are in a lot of surplus. We are probably not going to see interest rates come down to super-low levels anytime soon—well, who knows? If the economy does particularly badly, they may well do. My first question is, do you see any increased risk as a result of this? You are presumably looking at the risk of having to pay out. Secondly, should the benchmark be slightly higher for surplus distribution? Michelle Ostermann: Obviously, just as you describe, because we backstop the entire industry, what we are watching most closely is the fundedness of schemes, combined with the credit quality or the covenant, and the financial stability of the organisation itself. Those two combined are what help us to assess industry-wide risk and determine how much reserve we need to set aside for future claims on the PPF. There is a spectrum of schemes out there, clearly—some that are very well funded, which you have been speaking of, and several that are not as well funded. On that spectrum, our focus is on the left side tail—the ones that are most underfunded, or nearing the potential to be underfunded. Given the measures that are being discussed for the release of surplus, we at the PPF feel comfortable with it not imposing a material amount of risk to us, as it is currently defined. It seems to find a nice prudent balance between allowing some flexibility for sponsors to use that money in hopefully a productive way, combined with the test to make sure they do not fall below a certain level, which would bring risk upon the industry and the PPF. We have been a constant participant in that conversation, and we would like to suggest that we will continue to play that role as a surveyor of the net residual impact to the industry.

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27. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q Do you stress test the pensions industry in the same way as the Bank of England stress tests the banking system? Michelle Ostermann: Yes—it is very similar.

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28. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    And you war game it? Michelle Ostermann: Yes. The biggest variable that we have a hard time predicting in those scenarios is the likelihood of this being used and the manner in which it is used, but we test deep into the tail. We try several scenarios that give us a high probability of it being abused or overused, and the opposite, and we have come out with pretty strong confidence. As it is defined today, we feel comfortable.

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29. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q I must ask a question that is perhaps a self beat-up, if you like. There was a disastrous mini-Budget a few years ago under a different Prime Minister—of course, at the time, we got rid of our bad leaders. Did you stress test a scenario such as that? Michelle Ostermann: Not here in the UK, but as you can tell by my accent, I am not a local. I worked in Canada for most of my career, at two of the largest Canadian “Maple Eight” pension plans, and those are things that we would assess quite regularly. In fact, the open DB schemes here in the UK function very similarly to those in Canada. I joined the PPF in large part because it is a mini-version of the Canadian model. It is exceptionally similar, to me. You will notice that during the liquidity crisis that occurred it was the liability-driven investment strategies, with the degree of leverage, that were most at risk, and it was interest rate-sensitive. Those open DB schemes that were using a more balanced degree of risk, including some equity risk, were unencumbered. It was Railpen, which I worked for when I was here previously. I was phoning back to my peers both there and at the universities superannuation scheme and PPF, and they all withstood that very well.

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30. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q So while we were all running around like headless chickens trying to figure out what was going on, you were saying, “We told you so. We knew that was going to happen.” Michelle Ostermann: It is definitely something that was on our radar. When we build the investment strategy for an open DB scheme, such as those I described, it is quite different and less susceptible to that type of risk.

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31. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q Obviously, the most controversial part of the Bill is mandation—or rather, reserved powers for mandation; I am corrected by the Minister, who is flashing me interesting looks. Why do you think it is that Canadian pension funds are investing more into UK assets than British pension funds are—without being mandated? Chris Curry: We heard a little about that from the previous witness, who I think also has first-hand experience of the Canadian investment models, but there are a number of different reasons. First, there is the aggregation in the system that was talked about; the UK has a very fragmented pensions system. There are a number of different large sectors, but each large sector is not large internationally speaking. Scheme maturity, scheme size and scale generally are a factor. Very few individual schemes have the scale and the amount of assets to invest large-scale in some of the UK opportunities in the way that Canadian schemes have invested on a large scale—as has been said. Half a billion pounds to £1 billion in a single investment is very large by UK standards, compared with the size of schemes. There is also, because of that lack of scale, a lack of development of the expertise required by some of those specialists—sophistication has also been mentioned—across some of the different individual schemes that we have in the UK. If you are larger, you can afford to have those specialist management teams or specialists on the board. It is not such a proportionate cost as it would be to a relatively small scheme. Cost is another factor. As we heard from previous witnesses, in the UK a lot of focus on schemes has been on the cost of providing a scheme; in the workplace especially, by default a lot of competition is based on cost. With some of the opportunities we are talking about, especially in productive finance, in the UK space, investing in the UK would come at a high cost, so there is less scope for that cost to be absorbed in an overall larger fund. A lot of the things that the Bill is trying to address are probably some of the reasons why we have not seen that UK investment up until this point.

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32. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q A previous witness, Michelle Ostermann, made two really interesting related points. One is that, having derisked the UK pensions industry, there is not the appetite to make some of these investments. The second is that other countries are much better at leveraging their pensions industries in order to promote economic growth. Is that something you have looked at, William? William Wright: Certainly on the derisking side, while we are blessed to have the second or third largest pool of pensions assets in the world, the structure of our pensions system—the fact that so many DB schemes have closed or are running off—means that the overall risk appetite simply is not there. There is a danger in this debate of comparing the outcomes that we see in different types of pension fund systems around the world and thinking, “We like the look of that. Can we have a bit of that, please?” I am simplifying here, but we tend not to be too keen on looking at the inputs and the decisions, often taken 20, 30 or 40 years ago in different markets around the world, that have helped to lead to the development of those systems as they are today. The Canadian public sector defined-benefit model did not happen overnight. Michelle knows the history of it better than I do, but it goes well back into the 1980s. That is why so many of the aspects of the Bill should be welcomed. They look at the fundamental drivers of what will help to define pension fund outcomes for members and the structure of our system in 10, 20 or 30 years’ time. On how other systems think about pension systems in relation to growth and economic wellbeing in their domestic markets, one of the things that we found particularly striking is that when you compare DC pensions in the UK with DC systems in other countries, or public sector DB in the UK with public sector DB in other countries, there tends to be, for DC pensions in other countries, a higher domestic bias. There tends to be more investment, whichever way you look at it, in their domestic equity market than we see from UK DC pensions in the UK equity market. You also see, almost universally, higher levels of investment in private markets. So much of that comes back to scale. Scale is a threshold—it is not enough on its own—and then there is the sophistication, governance and skillset that needs to be built over many years on top of that.

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33. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q On this derisking thing, a number of investment managers over the years have pointed out to me that the rules were brought in as a result of Maxwell absconding and taking a lot of money out of his pension fund. Deficits are now placed on to the balance sheet of the host company, which means that the inclination of those companies is to prefer those pension funds to be invested in less volatile assets, not equity markets, where you can have a stock market crash one day as a minor correction in a long-term growth market. Do you think that is the kind of thing that Michelle was referring to in talking about derisking, where legislation that was well-intentioned at the time has had perverse outcomes? William Wright: Yes. As a number of witnesses have mentioned today, because of the structure of the UK pension fund industry, there are many different perspectives, often not entirely aligned, shall we say, with each other. Every participant in the industry has responded perfectly rationally to the incentives in front of them and the regulation behind them in their investment behaviour and risk profile. International accounting standards, rather than just UK standards, have helped to drive that in the private sector. We have seen similar derisking in other corporate DB pension systems around the world. It has been an entirely rational response. It is really interesting to see which elements of which markets around the world seem to have found a more positive response. Canadian public sector DB, the closest comparison to LGPS in this country, is one example. Others are Australian DC or some of the Nordic models—the Swedish and Danish DC models.

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34. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q Chris, following on from the points about derisking and all the rest of it, we heard from Phoenix a little earlier about the value for money framework. Everybody seems to agree that the framework is a good thing because it is going to drive better performance and all the rest of it, with one exception, expressed by Phoenix: the consequences of an intermediate rating. It is one of those difficult things where you seek mediocrity rather than going for good performance. Do you think that is a valid criticism of that particular part of an otherwise welcome part of the Bill? Chris Curry: First, I agree that we have seen lots of positive response to the value for money framework. Looking across international examples—Australia, in particular—it seems as if it will be very welcome in trying to ensure that, as part of the consolidation and what is potentially coming with the next Pensions Commission, with more investment going into UK pensions, that investment is going into a place that is actually going to work on behalf of the members who are investing their money. That is really important in what we are doing. I would also echo some of the views we heard earlier that it is really important in moving away from just a cost-based analysis of pensions and into value, and in looking at the whole range of different factors that are going to determine whether you get a good outcome rather than just at how much the investment costs. There are challenges. What we have seen in particular, which Tim mentioned earlier and echoes what we have seen in Australia, is that where you have a very hard measure over a relatively short period of time, that will affect investment behaviour. Because there is such a penalty for falling behind over a short space of time, you do everything you can to avoid falling behind, and there is fairly conclusive evidence that that has led to herding of investments in Australia. That is not to say that a framework, or even an intermediate marker, necessarily has to lead to that; I think that depends on the parameters you set and whether you are looking at the returns over one year, three years or five years, and how that works. Ideally, recognising that pensions are a long-term investment, you would not want to be looking too much at what happens over a short period of time in investment markets; you would want to be looking over a much longer period and at how the underlying strategy is performing. That is always very difficult, and one of the challenges is trying to get the balance right between what you can measure objectively and what you can measure subjectively. Where you are looking at things like an intermediate report, you tend to be looking at something that is objective, and it is quite difficult to do that over a long period of time. There is always a balance to be struck as part of this, and it would be good to investigate that more as we get further through this process, to work out the best way of doing it in order to achieve the best outcome for members.

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35. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    If I remember rightly, the Bill allows for the detail to come in afterwards, so we will have a bit of work to do when this is all over. Thank you very much.

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36. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q Thank you very much for the work you are doing on behalf of pensioners—it is important. Mr Sainsbury, the PPF has some £14 billion in reserves. Could you share with us the main arguments for and against using that to benefit PPF and FAS scheme members? Roger Sainsbury: In the light of Terry’s extended life history, I will just add that I am a fellow of the Royal Academy of Engineering and a former president of the Institution of Civil Engineers. Before I come to your important question, I would like to feel sure that everybody in this room really understands the huge seriousness of the issue we are considering. This business of removing indexation from people who had pensionable service prior to 1997 has been going on for 20 years. Many of the people involved have seen the value of their payments eroded by maybe even more than 50% in that time. It is really very serious. The second thing I would like to mention is that the scale of the problem is actually greater than the Post Office managers scandal. Of course, I am not suggesting for a moment that any of our claimants is suffering in the appalling way the postmasters did, but the numbers of our people are so huge compared with the postmasters that the actual amount of money at stake is greater. We have 140,000 PPF members who are affected by this bizarre clause of limiting the indexation, 60,000 of whom are 80 and have zero indexation, so it is a truly serious thing. I would also like to mention one other dimension, which is timing. In our written submission to the Committee, we did not even bother to press the basic argument for why indexation should be awarded; we just focused on timing, because time is absolutely not on our side at all. Our claimants are dying, on average, at the rate of 15 a week—it is probably three while we have been holding this meeting this afternoon—or 5,500 a year. We have been told by the Department that the necessary amendment to the Pensions Act 2004 cannot be made by statutory instrument. There would have to be a new Bill and a new Act, and goodness knows how many years that might take or how many more thousands of people would have died. That is why we are pressing to get an amendment to this Bill to give a more timely answer. Now I come to your question: what are the main arguments for and against using the reserves to benefit the members? Well, the first argument is simple, but really rather powerful: it is the only purpose that, legally, the PPF is allowed to spend its money on. The Act is very clear: unless some legal judgment was made against them, which is not on the horizon at all at the moment, the only way they are allowed to spend money is either on their own overheads or on giving benefits to members, such as the indexation that we are now talking about. That is reason No. 1; reason No. 2, in my mind, is that expectations have not been met and promises have not been fulfilled. I go back to the Secretary of State who introduced the Second Reading debate on the 2004 Bill. He pledged that pension promises made, by the original schemes that people were in, must be met—that is, met by the PPF, which is the reason why the PPF was to be, by that Act, created. Yet that has not happened because, somehow, into schedule 7 to the Act came these dreadful words that have had the effect of not permitting the PPF to pay any indexation at all to people for time worked prior to 1997. The third reason—ultimately, this is the important reason—is that the 140,000 people need this money. They desperately do, some of them. I mean, obviously not everybody’s condition is the same, but a lot of people will be suffering real misery and hardship. They need this money. I ask myself: “Were this Government elected on promises of governing with humanity and compassion? Are this Government going to meet that need? Or are they going to walk by on the other side?” I do not myself believe that they are; I believe that they will come up to the mark and find a way through the perceived difficulties that they have. I think those are probably sufficient reasons to be going on with; as to the reasons against granting this, frankly, I cannot see any.

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37. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q Well, there is one, which I would like to test both your opinions on. The Government point out that the reserves are on the public sector balance sheet, and therefore are treated as an asset of the Government, which is obviously offset against Government debt. Do you think that is a justifiable reason not to— Roger Sainsbury: Well, if— Terry Monk: Can I have a go? Alan, who is sitting behind me, and all of us say that we did the right thing at the right time to secure our futures. There was no risk—we were guaranteed there was no risk. The minimum funding requirement was seriously flawed post-Maxwell. That changed it. We were told our pensions were safe. They were no longer safe—I found out to my cost, and many others did, that our pensions were not safe. If I try to use the argument to our members that are still alive, “We can’t give you these increases because of the national accounts,” they will say, “Hang on, I did the right thing. I was told my pension was safe. I did the right thing all the way along in my life, and I saved for my future—for my comfortable retirement. I did not want to depend upon the state. I wanted to do it for myself. That is what I was proud to do.” To use the argument that the national accounts do not allow these people to get their benefits? I could not use that argument, whatever the reasons might be behind it. Roger Sainsbury: May I try to answer your question more specifically? I think that indexation would have an impact upon Government finances. The impact would be that cash would flow into the Treasury, because if indexation is permitted and starts to be paid, there will be income tax paid on that money. The money will be going out from the private funds of the PPF, but the income tax and subsequently the VAT on expenditures will be coming into the Treasury coffers. I have yet to meet anybody, other than people in government, who can comprehend how it can be that when the PPF, from its private funds, meets an obligation, which has the incidental effect of bringing cash into the Government coffers, that can at the same time lead to a failure to meet the fiscal rules. The fiscal rules, incidentally, are set up for a period of four years, when the unravelling of the indexation obligation will take many decades. We have been told in ministerial letters that it has been set up this way with a view to improving transparency. Well, I am sure you have all heard of the fog of war, but I think we are now up against the fog of transparency. I do not think it is real money that the Government are talking about. Even in their own letters, they say it is a statistical way of handling the figures. The recent Government line on this is that it is the fault—I do not want to put blame on anybody—or the responsibility of the Office for National Statistics, because it was the Office for National Statistics that decreed that the assets and liabilities of the Pension Protection Fund should be counted as part of the public sector national financial liabilities, rather than as part of the public sector net debt, but that decision was made in 2019. We are therefore more inclined to hold responsible the present Chancellor, who, in her Budget of last October, made the decision that, for the Government financial rules, the metric should no longer be the public sector net debt, but the public sector net financial liabilities. It was that that brought the PPF, as it were, on to this part of the playing field.

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38. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    That is very helpful, thank you. I am very conscious that other Members will almost certainly have questions, but I must say that I entirely agree with you that a sum of money set aside for compensation should not be brought into the Government’s balance sheet.

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39. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q Thank you very much, and thank you for coming in this afternoon. I do not know how much of this you have listened to, but there are a lot of worries about mandation coming in on pension funds. Of course, this does not include the local government pension scheme, because this is about defined contribution pension funds. However, there are measures in the Bill that enable the Secretary of State to have the powers to issue directions and guidance to local government pension scheme pools. Do you worry that these could be mandation by another method? Rachel Elwell: The LGPS is already investing significantly in the UK, as you have probably already heard. We invest more than 25% of the assets we look after on behalf of pension funds in the UK, and there is a very good reason for that, which I can explore a bit further if you would find it helpful. To answer the specific question, I am not concerned that the power will instruct the LGPS to invest in specific things. I think there is a real intent; it would be helpful if the Bill were clear that it would not be against fiduciary duty and would not interfere with the FCA regulations that we are also subject to. I am very thoughtful about how we carefully manage the weight of capital that might come into the market if there is mandation for the wider industry to move quickly into investing in the UK. Work will need to be done on the supply side as well as the capital side, to ensure that the UK can invest well the capital that should be being invested into the UK. So it is important that any use of mandation is very carefully considered, and that the laws of unintended consequences are really thought through.

    Hansard source
40. 2 Sep 2025·Parliament·Mark Garnier

    Pension Schemes Bill (Second sitting)

    Q Do you think there is a risk that mandation could come in on the LGPS by subtle, behavioural outcomes rather than necessarily through directive outcomes? Rachel Elwell: I can understand why the Government would want to have a backstop power to direct pools, because the LGPS is significant—it is one of the top 10 globally by size. It has an impact on council tax, and on the economy more generally. If you have a pool that is not delivering and all the other mechanisms available to their stakeholders have failed, I can understand why that power would exist. But it is important that we clear the scenarios in which it is envisaged that it might be used.

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