Guest comment: Simplifying DB funding regime reporting

We published new research showing that most UK defined benefit (DB) pension schemes are already well funded and clear on their long-term plans – with the new funding regime seen primarily as a compliance exercise rather than a driver of change.

We call for The Pensions Regulator (TPR) to urgently simplify its submission for schemes to comply with the statement of strategy requirements.

Based on 156 responses from scheme actuaries across a wide range of UK pension schemes, the survey highlights a system that is largely progressing towards endgame strategies such as buyout or running on, with limited influence from the new regulatory regime.

The findings suggest that the DB system is largely well funded, the new funding regime is seen as administrative rather than transformative, and surplus flexibility may become the more important policy lever in shaping future behaviour.

The survey also finds early evidence that new surplus flexibilities under the Pension Schemes Act 2026 are prompting discussions, particularly among larger schemes.

What is interesting is surplus reforms are starting to shape conversations between pension schemes and employers.

The devil will be in the detail as the Department for Work and Pensions’ (DWP) regulations and TPR’s associated guidance are formed.

We look forward to helping shape a clear, workable DB surplus-release regime which properly balances the release of surplus with adequate clarity and confidence for employers, appropriate safeguards to members’ benefits, and aligns appropriately with trustees’ duties



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