Independent Governance Committees


Since 6 April 2015, providers that operate workplace personal pension schemes have been required to set up and maintain an IGC.

IGCs have a number of statutory duties, including producing and making publicly available an annual report with information on value for money and how the IGC has complied with its duty to act in the best interests of members. IGCs do not currently have the same powers to enforce changes as trustees of occupational pension schemes. However it seems likely that the remit of IGCs will develop significantly as the range of in-retirement products expands.

We help IGCs to assess value for money and put in place a verification process to ensure FCA principles are met. We also advise on the governance of IGCs and the documentation of their decision making processes, as well as preparing them for discussions with the FCA, and any issues arising from the Independent Project Board (IPB) report and provider action plans.

Recent experience

  • Advising providers on the regulatory requirements for IGCs and how these can be met
  • Advising providers on legal issues arising from changing policy holders’ default investment strategies and moving policy holders from one product to another without consent
  • Advising IGCs on the content of their annual report and the approach to be taken with key stakeholders
  • Advising IGCs on value for money and putting in place a verification process to ensure FCA principles are met
  • Co-ordinating a major member research study on attitudes to value for money for 11 providers and their IGCs.