Hogan Lovells

Key Dates

Response to consultation and two sets of final statutory guidance issued by the DWP on 21 June 2021.

Consultation “Incorporating performance fees within the charge cap” issued in March 2021.

Consultation on draft regulations and statutory guidance to deliver better value for money for DC members issued on 11 September 2020.

The draft Occupational Pension Schemes (Administration, Investment, Charges and Governance)(Amendment) Regulations expected in force on 1 October 2021.

Statutory guidance “Reporting of costs, charges and other information: guidance for trustees and managers of occupational schemesand Completing the annual Value for Members assessment and Reporting Investment Returns: Guidance for trustees of relevant occupational DC schemes” both to be effective from 1 October 2021.


The DWP has issued a consultation response, revised amending regulations and statutory guidance to give effect to its proposals to require smaller schemes to carry out enhanced value for members (VFM) assessments.  The statutory guidance also covers the new requirement to report net investment returns, applicable to all relevant DC schemes.

At the same time, the DWP issued a call for evidence on how to accelerate consolidation of DC schemes with less than £100m of assets, which it considers more likely to offer poorer VFM than larger schemes. 

The DWP has also issued revised statutory guidance on reporting costs, charges and other information. 

Enhanced VFM assessment for small schemes (statutory guidance and amendments to regulations)

Comparison with larger schemes

Assessment of governance and administration

Action following a poor enhanced VFM assessment

Valuing legacy funds for enhanced VFM assessments

Date Accessed: 03/12/2021