PA Autumn Conference: PSB is an 'incomplete' package despite 'forceful and urgent' drafting

The Pension Schemes Bill is an "incomplete package", Sackers partner, Andy Lewis, has said, warning that despite the "forceful and urgent" nature of the bill, it will not fully address all the policy drivers identified by the government.

Speaking at the Pensions Age Autumn Conference 2025, Lewis clarified that "overall successful pensions policy is going to involve addressing a number of huge challenges, which the bill simply does not cover".

He suggested the bill will bring “profound and comparatively rapid” changes to the Local Government Pension Schemes (LGPS) and to a large part of the defined contribution (DC) market, and that the changes in the defined benefit (DB) sector, although less extensive, are expected to be "helpful to some" in the right circumstances.

"What stands out most to me," he said, "is the strongly interventionist flavour of this bill, backed by strong regulations and strong powers of the regulators. This is a law that's forceful and urgent."

However, Lewis clarified that despite these benefits, "it's an incomplete package and it's not going to completely resolve all the policy drivers the government has identified".

Lewis added that while solutions to the policy drivers may yet come, "fundamentally, the outcome and the good for members is going to depend on all of us in the industry for doing our bit".

In addition to this, Lewis stressed that the bill's success will depend on the prioritisation and delegation of tasks by governing bodies, but warned that the industry only has limited capacity.

“The changes driven by the Pension Schemes Bill will inevitably need to fit alongside multiple other priorities, and we must recognise that there is only so much bandwidth in key areas of the industry," Lewis said.

“If it has to do too much at once, there is a risk that none of it will be done well. Success will depend on prioritisation and governing bodies delegating effectively. In the long run, it will pay dividends to make a clear plan for how time and resources are allocated to each issue.”

Lewis also stressed the importance of non-lawyers understanding that the Pension Schemes Bill is “just a framework”.

“All of the measures are going to need further legislation from the Department for Work and Pensions and others before the industry can start putting things into practice, meaning that many of the key operational details that we will all need to know and are not authorised at this point,” he said.

He also noted that when considering member outcomes, there are “some gaps” in the bill, and he believes that these areas remain the responsibility of the industry as a collective to act on, even after the bill comes into law.

For example, Lewis said that in the DC space, adequacy had to be “absolutely a top priority".

“It's good news that the Pensions Commission has been set up and revived to look at that, but it's going to take some time for the commission to gather evidence and collect recommendations," he continued.

“And we're going to need to think within that about whether the framework is enabling pension saving and whether it is adequately addressing gaps for women and other groups who've been traditionally underserved by the current pension saving model."

In addition to this, he predicted the bill would also spark wider debates, including how to ensure the member voice is recognised and valued in a landscape with fewer, larger schemes.

He suggested there could even be a more “fundamental debate” about the future of single-employer DC trusts, weighing the benefits, such as special benefit features and the ability to use DB surpluses to fund DC contributions, against the growing compliance pressures these schemes will face.

Lewis also highlighted investments and fiduciary duty as something missing from the bill, arguing that it is now “apparent and urgent” that the industry has legislation to clarify fiduciary duty for pension schemes, and make it fit for purpose for investment in the 21st century.

“I think that can be done in a way that's permissive and that enables schemes to retain autonomy over how they invest but provides a safer and stronger legal foundation for doing so,” he said.



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