01 July 2021

Henry Tapper, chief executive officer at AgeWage, outlines developments

In a surprise statement (Publication of costs and charges data by workplace personal pension providers – https://bit.ly/3zyMHgb), the Financial Conduct Authority (FCA) has admitted it has not given providers of workplace group personal pensions (GPPs) sufficient clarity on what it wants them to disclose. The statement says: “Some stakeholders think that costs and charges data should be published at the level of the overarching HMRC registered scheme, with the data indicating a range of charges paid by members in different employer arrangements within that overarching scheme.

“We don’t consider that aggregation of costs and charges at the level of an overarching scheme would promote meaningful comparisons, however. Instead, comparisons at the employer level could play a useful role in helping to improve value for money in workplace pensions.

“However, some firms have told us that they were unclear at what level disclosures were required and have been preparing disclosures at registered scheme level.”

The FCA are consulting on fuller disclosures in future years, but the disclosures that will be published this scheme year (by 31 July) go considerably further than any information previously published. Employers can look forward to some interesting disclosures, not least an understanding of what other employers participating in the same ‘HMRC scheme’ are getting by way of a deal.

Workplace pension independent governance committees (IGCs) will need to either:

  • disclose each set of costs and charges that they levy (and the number of employer schemes which have these costs and charges), or
  • show the distribution of costs and charges by employer arrangement in some other way, for example by dividing the range of charges into deciles (i.e. without also disclosing the relevant employer or scheme details against the particular costs and charges).

In my experience – I was head of sales at Zurich/Eagle Star 1995–2005 – employer scheme pricing was based on what margin we could agree with the gatekeepers (the employee benefit consultancies). These gatekeepers worked on ‘leaving something on the table for the next man’, which added up to providers getting deals at pretty favourable prices to the insurers.

The schemes which were set up at the turn of the century with no assets are now looking very healthy; if your employer pension has £100,000,000 in assets the provider is earning £1,000 annually for every basis point (0.01%) of charge they are making. The range of charges is between 0.1% to 0.75% so there is considerable scope for negotiation – and the FCA know it.

Indeed, the statement the FCA put out early in June shows that they are now on top of this subject and have grasped how important it is that employers are empowered to understand their costs. The FCA sees the disclosure of charges at employer level as meeting three statutory objectives:

  • Competition – Scheme members and others can access better information about costs and charges, promoting more effective competition between firms in the interests of consumers.
  • Consumer protection – Better information about costs and charges should enable scheme members to decide if their scheme is giving them value for money and if it will meet their future needs.
  • Market integrity – Workplace pension schemes should be better-held to account by their members, which would improve the orderly operation of the financial markets.

I think it ambitious to expect members to be picking up on costs and charges they are paying, through disclosures from the IGCs. However, employers have the capacity to be more assertive. And I see an opportunity for human resources, reward and payroll departments to benchmark themselves and renegotiate charges for staff either with the existing provider, or by switching to a rival.

The problem for employers was correctly identified by the Office of Fair Trading in 2013, when it wrote in its market study: “The buyer side of the DC [defined contribution] workplace pensions market is one of the weakest that the OFT has analysed in recent years. Part of the reason for this is that most employees do not engage with or understand their pensions. Pensions are complicated products, the benefits of which occur a long time in the future, for many people.”

Consumerists have long argued that employees did not have the information to make sense of their pension pots. But moves are afoot at both the FCA and The Pensions Regulator to make sure savers in workplace pensions have simple pension statements that tell them the costs they are paying, published by law. So, both employers and members will be better empowered to take decisions – and soon!

Of course, employers should not be making purchasing decisions just on price (value is the other part of the equation), but this move from the FCA should be picked up on by every employer that runs their workplace pension as a GPP (and by many who participate in master trusts and have their own company workplace pension). 


Featured in the July/August 2021 issue of Professional in Payroll, Pensions and Reward. Correct at time of publication.