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FCA

FCA

Financial Conduct Authority (UK)

Medium Impact

FCA consults on updated Value for Money Framework proposals for workplace pensions (CP26/25)

Published

Jul 10, 2026

Topics

Workplace pensions, Defined contribution pensions, Value for Money, Independent Governance Committees, Governance Advisory Arrangements, Pensions reporting, Asset allocation

Executive Summary

On 13 July 2026, the FCA published CP26/25, an updated consultation on the Value for Money Framework for workplace pensions. The consultation is aimed at firms operating contract-based workplace pensions, IGCs, GAAs, trustees and sponsors of trust-based schemes, pension service providers, employers, consumer bodies and other interested stakeholders. The consultation closes on 1 September 2026. The FCA states that the updated proposals reflect feedback from the previous consultation, CP26/1, and seek a proportionate, effective and deliverable framework while maintaining consistency across trust-based and contract-based workplace pensions as far as possible. Subject to the consultation outcome, the FCA intends to introduce rules and guidance for the VFM Framework in 2027. In parallel, subject to Parliamentary agreement, DWP and The Pensions Regulator plan to introduce regulations for trust-based arrangements. Larger schemes, including Master Trusts, large single employer schemes and multi-employer contract-based schemes open to new employers, are expected to complete VFM assessments from 2028, with rollout to all in-scope schemes from 2029. Firms should treat this as a material change programme rather than a final rule implementation date, because the current document is still a consultation.

What Changed

modifiedUpdated VFM Framework consultation following CP26/1 feedback

Previous

Earlier proposals were set out in CP26/1 and prior FCA consultation material on the VFM Framework.

New

CP26/25 is the current consultation and is open from 13 July 2026 to 1 September 2026.

newConsultation response routing through DWP VFM Policy Team

Previous

No routing detail is identified in the supplied source for CP26/25 before publication.

New

Responses should be sent to the DWP VFM Policy Team by the consultation deadline.

modifiedIndicative implementation path for rules, guidance and assessments

Previous

Earlier consultation stages set out detailed VFM Framework proposals for workplace defined contribution pension schemes, but CP26/25 provides the current stated next steps and rollout sequencing.

New

FCA rules and guidance are intended in 2027, larger scheme assessments from 2028, and rollout to all in-scope schemes from 2029, all subject to consultation outcome and, for trust-based arrangements, Parliamentary agreement.

newAsset allocation survey evidence linked to the consultation

Previous

The supplied source does not identify this CP26/25-linked survey evidence as part of the earlier consultation stage.

New

The CP26/25 page links to the results of the FCA asset allocation survey and notes a similar TPR exercise for Master Trust schemes.

Business Impact

Who is affected

Firms operating contract-based workplace pensions; Independent Governance Committees; Governance Advisory Arrangements; trustees and sponsors of trust-based schemes; Master Trusts; large single employer schemes; multi-employer contract-based schemes open to new employers; pension scheme service providers; employers; pension administrators; and consumer or civil society organisations with an interest in pensions and financial capability.

Jurisdictions

United Kingdom

Business processes

Regulatory change management and consultation response, Workplace pension governance, Value for Money assessment design, Default arrangement oversight, Investment performance and asset allocation data readiness, Scheme cohorting and implementation planning, IGC and GAA reporting and challenge processes, Engagement with DWP, FCA and The Pensions Regulator

Estimated effort

Medium

Compliance risk

Medium

Affected Reports

Value for Money assessment for workplace pension schemes (proposed framework; larger schemes from 2028 and all in-scope schemes from 2029, subject to final rules and regulations)CP26/25 consultation response to the DWP VFM Policy TeamAsset allocation data evidence used to support VFM Framework policy development
FieldValidation rule
Consultation response recipientCP26/25 states that responses should be sent to the DWP VFM Policy Team and will then be shared with the FCA and The Pensions Regulator.
Consultation response deadlineCP26/25 states that the consultation closes on 1 September 2026.
Initial VFM assessment cohortCP26/25 states that from 2028 larger schemes, including Master Trusts, large single employer schemes and multi-employer contract-based schemes open to new employers, will complete VFM assessments.
Full VFM assessment rollout populationCP26/25 states that changes will be rolled out to all in-scope schemes from 2029.

Recommended Actions

  1. 1

    Assign an owner for the CP26/25 consultation response and coordinate input from pensions product, investment, governance, legal, compliance, data and operations teams before the 1 September 2026 deadline.

  2. 2

    Map the firm’s contract-based workplace pension arrangements, IGC/GAA oversight arrangements and multi-employer scheme status to determine whether the business may be in an early implementation cohort from 2028.

  3. 3

    Review current VFM, default arrangement, investment performance, charges, service-quality and asset allocation data sources against the expected assessment capability implied by the FCA’s VFM Framework programme.

  4. 4

    Engage IGCs and GAAs early so they can challenge proposed implementation assumptions and contribute to the consultation response.

  5. 5

    Monitor the FCA, DWP and The Pensions Regulator for the 2027 rules, guidance and trust-based regulations before committing to final systems specifications.

  6. 6

    Treat 2028 and 2029 as planning milestones, not final legal effective dates, until the FCA publishes final rules and guidance and DWP/TPR publish any applicable trust-based regulations.

Timeline

publication

Oct 18, 2024

FCA published CP24/16 consulting on detailed rules and guidance for a new VFM framework for savers in default arrangements of workplace defined contribution pension schemes.

publication

Jul 13, 2026

FCA published CP26/25: The Value for Money Framework consultation.

other

Jul 13, 2026

CP26/25 consultation opened.

consultation deadline

Sep 1, 2026

Deadline for responses to CP26/25.

implementation

Jan 1, 2027

Subject to consultation outcome, FCA intends to introduce rules and guidance for the VFM Framework; DWP and TPR plan, subject to Parliamentary agreement, to introduce regulations for trust-based arrangements.

implementation

Jan 1, 2028

Larger schemes, including Master Trusts, large single employer schemes and multi-employer contract-based schemes open to new employers, expected to complete VFM assessments.

implementation

Jan 1, 2029

FCA states that the changes will be rolled out to all in-scope schemes from 2029.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

Related Evidence

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