ARTICLE
15 April 2025

UK Pension Schemes: Opportunities For Private Capital Across Defined Benefit And Defined Contribution

M
Macfarlanes LLP

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With an estimated market size of approximately £4tr, the UK pension market is the largest in Europe and second largest in the world after the US.
United Kingdom Employment and HR

Introduction

With an estimated market size of approximately £4tr, the UK pension market is the largest in Europe and second largest in the world after the US. The market is evolving in a number of ways as multiple consultations and policy changes have been proposed across defined benefit (DB) and defined contribution (DC) schemes.

Overall, three broad themes can be identified:

  1. consolidation/scale;
  2. increasing investments in private assets; and
  3. increasing investments in the UK.

Pensions have been a priority on the political agenda with both the Conservative and Labour parties agreeing that pension assets should be better utilised to grow the UK's economy, a topic our public policy team explored in a recent article on privatecapitalsolutions.com.

Given this shared agenda, the new government will be able to build on the work already undertaken by the outgoing administration, such as previous consultations. Officials have long been focused on this area and have refined their policy advice both in light of the direction of travel set out by Jeremy Hunt – the previous Chancellor of the Exchequer – and the similar approach taken by Rachel Reeves, the new Chancellor, in opposition. The Pension Schemes Bill, announced during the King's Speech in July, further indicates that the change of government will not disrupt policy development in this area, as the measures proposed mostly echo those of the previous administration. That said, it appears that the new government is eager to move quickly having already published an interim report for its landmark Pension Investment Review and a series of consultations.

In this report we intend to take stock of the ongoing reforms and their impact on each sub-sector of UK occupational pensions and the opportunities and challenges they may pose for private capital.

Report update: Recent changes at a glance

The new government has wasted little time moving forward with reforms to the pensions market. This report was first published in October 2024 but has been updated for the recent activity in this space. This page provides a summary of the latest developments and how they affect private capital managers.

Public DB schemes
Policy development Summary Latest activity Opportunity and risks for private capital managers
Scale and consolidation via pooling of assets The government is seeking to accelerate the pooling of LGPS assets to better capitalise on investment opportunities and deliver economies of scale.
  • The government has proposed pooling all LGPS assets by March 2026. The government issued a consultation "Local Government Pension Scheme (England and Wales): Fit for the future" on the subject which closed on 16 January 2025 and the Minister for Pensions, Torsten Bell confirmed intentions to move forward with this proposal in a speech at the PLSA Conference (11 March 2025).
  • Scale is expected to lead to greater capacity and capabilities to invest in more diverse and large-scale investments in private markets. This will in turn increase the pools' bargaining power, therefore managers may face more fee pressure.
  • From March 2026 individual LGPSs will no longer be able to make any direct private capital commitments, all investment will be made through the pools.
Investment in productive asset classes The LGPSs already invest c30% of their assets in the UK. The government has stopped short of advocating targets for UK investments. It will however place more pressure on LGPS pools to unlock investment opportunities in "local" business and report annually on this.
  • Government consultation "Local Government Pension Scheme (England and Wales): Fit for the future" closed 16 January 2025, more details on local investment are expected in the final Pensions Review report due Spring 2025.
  • No targets have been set to tie LGPS funds to a certain threshold of domestic investment, however they will be required to report annually on their local investments.
  • The government recognises that identifying and assessing the suitability of local investments requires resources for intensive due diligence, therefore there may be a role for the private capital sector to help identify "local" investments and support the development of local growth plans.
Surplus sharing The government is considering options to improve access to DB pension fund surpluses. Releasing the surplus funds is hoped to encourage pension funds to defer the transfer to an insurance company and therefore reverse the immediate de-risk strategy and increase investment in growth productive assets.
  • In January 2025, the Chancellor stated that "pension trustees and the sponsoring employers could then use this money to increase the productivity of their businesses – to boost wages and drive growth or unlock more money for pension scheme members." A consultation is expected in Spring 2025
  • The ability to benefit from surplus should encourage pension funds to increase investment in more growthorientated asset classes including private assets.
  • It remains to be seen whether the surplus will only be available for investment within the sponsoring employers' business or whether this mandate will be used to promote wider investment in private markets.
Scaling default arrangements The government has sought views on proposals to introduce a minimum AUM requirement for default funds and limit the number of default arrangements that each provider can operate. This is designed to accelerate a shift towards larger pension funds.
  • The consultation "Unlocking the UK pensions market for growth" closed on 16 January 2025.
  • Changes are unlikely to apply before 2030 due to significant market changes and the need for sufficient lead time.
  • Larger scaled funds will provide further impetus for investment in higher returning assets with greater resources and the ability to accept exposure to higher risk and more illiquid assets.
Investment in unlisted equities Eleven Mansion House signatories have committed to invest 5% of their default funds in "unlisted equities" by 2030, although this is not mandatory.
  • According to the FT the government is exploring ways to encourage Mansion House signatories to invest more in defence.
  • The Compact is due to be updated summer 2025
  • It is predicted that allocating at least 5% of DC default funds to unlisted equities could unlock £50bn of investment into private equity. There are calls to extend the target to other private assets.
Unconnected multiple employer pension schemes Collective DC schemes are designed to hold a greater range of higher risk assets by pooling a broader range of different ages and longevity risks through multiple unconnected employer trusts.
  • The Royal Mail Collective Pension Plan officially launched on October 2024. This is the UK's first Collective DC scheme (single employer).
  • The government consulted on draft legislations for multiple-employer Collective DC scheme during 2024 with final legislation expected in 2025.
  • Collective DC schemes have elements of collective risk sharing that do not exist in traditional DC schemes. This has the potential to allow for higher investment risk.
  • Scale is a critical element of risk sharing, meaning that the ability to have multi-employer schemes could increase the adoption of this pension type in the UK.
Value for money The government is developing a VFM Framework to shift the focus from short-term costs to long-term value for savers and increase transparency and competition in the market with pension funds expected to publish public information on their investment performance. This will involve greater disclosure on a variety of metrics (e.g. investment performance, asset allocation inc UK / non-UK split) which is designed to shift the emphasis from cost.

The government is also exploring whether employers place too much emphasis on the price charged by workplace pension providers compared to other metrics (e.g. investment performance).
  • The VFM Framework (initiated by the previous government) was due to be in place by 2027. The FCA undertook a consultation in summer 2024 and the theme of cost versus value was explored in the consultation "Unlocking the UK pensions market for growth" which closed on 16 January 2025. Although the timetable is not clear, it appears the current government remains committed.
  • The Pensions Minister, Torsten Bell, said in March 2025 he is looking at "reforms to focus more on value, and less narrowly on cost or price... we also need to focus on value in debates and, to be frank, in sales pitches."
  • The Pensions Investment Review (expected spring 2025) is also expected to comment on what further action might be required to drive the focus on value over cost.
  • Private capital will benefit from greater allocations where cost is no longer the primary indicator of performance, furthermore, the disclosure requirements around asset allocation may prompt DC pension providers to consider a wider range of asset classes into private equity and private debt.
  • Private capital managers may be required to provide more information or disclose information about performance in a certain way.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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