Sackers responds to the latest Value for Money (VFM) framework consultation

Sackers responds to the DWP’s consultation setting out a “detailed proposed approach” to the new VFM framework for DC schemes, along with draft regulations and draft FCA rules (see our Alert for details).

Helen Ball, partner, comments: “We welcome the recent progress that has been made in developing a more consistent approach to assessing value across the DC market. In particular, the move to a phased implementation timetable should ease some of the pressures on those who are preparing for the new regime.

As TPR’s overview confirmed on 11 August, the framework has been subject to a series of consultations but is not yet finalised.  Final regulations are due to be published in January and there will also be a separate consultation on a TPR Code of Practice in the first half of 2027. So we don’t yet have the full picture on what VFM will require of trustees and IGCs.

It would be helpful to have further clarity on the final requirements as soon as possible, so that the industry can start to prepare for the new VFM duties and plan their resourcing needs over the next couple of years.

In particular, we need details that would help schemes to identify and assess which arrangements are in scope, confirmation of which overlapping reporting obligations will be removed, and an explanation of how employer subsidies might impact in some way the assessment process.

Greater clarity will help trustees and IGCs apply the framework consistently and deliver its ultimate underlying objective of improving outcomes for members.

Read our full consultation response.