Industry experts from the Department for Work and Pensions (DWP), the Financial Conduct Authority (FCA) and The Pensions Regulator (TPR) have acknowledged concerns raised in response to the Value for Money (VFM) consultation, with a further consultation expected to address these issues.

Speaking at the Pensions Management Institute’s (PMI) Defined Contribution (DC) and Master Trust Symposium 2026, yesterday, 23 April, DWP deputy director for automatic enrolment and DC pensions policy, Rob O’Carroll, stressed that the current VFM framework should be seen as a “starting point”, with scope for further development.

“This is a starting point; it’s not the end. There is an opportunity for [VFM] to evolve,” he said.

The VFM framework, jointly proposed by the DWP, FCA and TPR, would require schemes to publish clear data on performance, costs and service quality, alongside a rating system designed to support easier comparisons between arrangements.

Responses to the consultation, which closed on 8 March 2026, highlighted a number of concerns from industry stakeholders.

O’Carroll acknowledged these concerns in the session, particularly calls for further testing before the framework is formally introduced, noting that this is “something we are carefully weighing up at this time”.

Another concern raised in consultation feedback was the need for greater clarity. Addressing this, FCA head of department for wholesale buyside market analysis and policy, Nike Trost, said regulators plan to use further consultation to refine the framework, which might also look at providing clearer definitions.

“We will consult one last time to make sure that we have one framework, with one set of definitions that everyone can then work with,” she said.

“I think we will use the next consultation to make sure that where we have questions about definitions, they are answered as much as possible,” she added, noting that the aim is to create a framework that is “more usable” and “more streamlined”.

In an earlier session, TPR director of DC and master trust supervision, Kim Goodall-Brown, described VFM as “one of the most significant shifts underway in DC” and said close coordination between TPR and the FCA is integral to its success.

“We're working incredibly closely together, not just on the policy, metrics and measures, and not just on how we developed this for distribution, but aligning our approach to managers and improving our communication, such as forming deeper relationships across our supervision and colleagues,” she said.

“If we want more consistency across the market in value, that has to start with the regulators.”

Goodall-Brown said TPR and the FCA “hear the concerns from the market about different expectations and different market messages at different times” and are working closely to address this.

“VFM is not just about investment performance – service matters and cost matters. We appreciate the concerns you're raising about having a single approach across regulators, and we are working very hard with the DWP and the FCA,” she concluded.

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