Pensions Bulletin 2019/18

Our viewpoint

Pensions Bill almost certainly delayed

In normal times we would expect a Queen’s Speech around now that would signal the Government’s legislative programme for the next twelve months and this year would include mention of a Pensions Bill to take forward the Government’s plans in a number of areas – most notably those signalled in the March 2018 DB White Paper (see Pensions Bulletin 2018/12).  We had been expecting to see the Pensions Bill before Parliament rises for the summer recess.

But these are not normal times.  As at the time of writing, it seems that the Queen’s Speech will not be any time soon, and quite possibly not before we have a new Prime Minister.  So, what does this mean for the Pensions Bill?  Almost certainly a delay, perhaps until late autumn.


Hopefully this delay will simply mean that the Bill, that is presumably being put together right now by the DWP, will be in better shape when it does have its first outing in Parliament.  But with the political situation so unstable we simply do not know what the next Queen’s Speech will contain, who will be the guiding hand behind its contents, and who will be in charge of the DWP once we have enjoyed the pomp and circumstance of the next State Opening of Parliament.

No need to stress about those tests

When we reported on the launch of EIOPA’s 2019 pension scheme stress tests in April (see Pensions Bulletin 2019/13) we commented that we had not yet heard from the Pensions Regulator about how it intended to approach the exercise given the uncertainties created by Brexit.

We now understand from discussions with industry bodies that the Regulator will not be requiring pension schemes to directly participate.  As before it will submit data to EIOPA on behalf of UK schemes.  However, schemes may still participate on a voluntary basis.


This is good news.  There had been some speculation that EIOPA would insist on more active participation from UK pension schemes this year.  Having to produce a great deal of detailed information in a prescribed and inflexible format to a deadline would have been an unwelcome burden for many trustees.

FCA examines intergenerational differences

The Financial Conduct Authority has published a discussion paper in which it seeks to open a debate on how the financial services industry and its regulators should respond to the different financial services needs of three generations – stylised as “Baby Boomers”, “Generation X” and “Millennials”.

The discussion paper starts by setting out its analysis of Office for National Statistics’ Wealth and Assets Survey data, which shows that the way in which consumers build and use their wealth has changed between 2006/08 to 2014/16.  It goes on to discuss the key socio-economic drivers that have contributed to this shift in wealth distribution and may contribute to wider intergenerational issues.  There then follows a discussion on what these trends mean for mortgages, pensions, consumer credit, and insurance and protection, before the paper summarises the implications of these trends for the three generations and asks whether their changing financial needs are being met.  The paper concludes with some wide-ranging questions.

Separately the FCA and the Pensions Regulator have published a research note that looks at the distribution of wealth holdings in Britain with the aim of shedding light on the distribution of wealth accumulation by age, how the distribution of wealth relates to differences in expected lifetime income and how those aged 60 to 65 are prepared for retirement.

Comments on the FCA discussion paper are requested by 1 August 2019.


The FCA’s principal concern behind this discussion paper is that financial services should meet the needs of different generations and that there should not be any unnecessary barriers or evidence of consumer harm.  It may well be some time before the FCA gets to setting down any new rules for providers – and before then the FCA needs to know whether its analysis is sound.

Master trust authorisation – the latest statistics

Another month on and the Regulator reports that five master trusts have been authorised (up from three at the end of March), 29 applications are being processed (up from 27) and five remain in the six week extension window (down from 10).  So, as at the end of April we are looking at a potential market of 39 authorised master trusts, although it seems that it will be some while before we get to a final landing.

The Pensions Regulator promises to keep publishing these end month reports until June and will of course continue to maintain its separate list of authorised master trusts.


The Regulator remains coy about precisely how those master trusts who are exiting the market are doing so, as well as who they are, leaving it to others to fill in the gaps.

This Pensions Bulletin does not constitute advice, nor should it be taken as an authoritative statement of the law.  For further help, please contact David Everett at our London office or the partner who normally advises you.

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