Pensions Bulletin 2025/19

Mansion House Accord announced 

The Pensions and Lifetime Savings Association has announced the Mansion House Accord. The Accord is separate to but builds on 2023’s Mansion House Compact announced by the City of London as part of the then Chancellor Jeremey Hunt’s Mansion House speech (see Pensions Bulletin 2023/28). It also marks another step in the Government’s push to increase UK pension investment into private markets.  

What the Accord says  

The Accord sees a wider set of DC providers and master trusts signing up to a target of investing a minimum of 10% of their default funds in private markets by 2030. And in a new development, at least 5% of their default funds are to be directed towards UK private markets. By contrast the 2023 Compact set an ambition of participants investing 5% of their default funds in unlisted equities by 2030.  

The Accord defines “private markets” as being those equities, property, infrastructure and debt/credit that are unlisted and “UK private markets” to mean where the underlying assets are based in the UK. The FAQs accompanying the Accord make clear that only provider-designed defaults, which are open to contributions, are in scope – not legacy defaults (which are expected to be consolidated in due course), nor bespoke defaults. Additionally, it is only assets in the growth phase that should be considered. The FAQs also make clear that these asset allocation ambitions will only be made where such investments are in members’ best interests and that trustees’ fiduciary duties are unaffected. 

The Accord says that the signatories consider the following to be amongst the critical enablers for a successful delivery of the Accord’s ambition: 

• A pipeline of UK investment opportunities, which the Government has agreed to facilitate.  
• The whole market, including intermediaries, to shift from cost to value, as well as successful delivery by the Government of the upcoming Value for Money framework. 
• Alignment between the Government and the FCA on that framework, on the scope of the charge cap and clarity in rules and guidance, and on delivery of the in-train policy change on bulk transfers without consent, when it is in the best interests of savers and subject to necessary safeguards. 
• A pragmatic, well-sequenced approach to the scale tests proposed by the Government in a way that ensures competition and innovation in the market and that does not prevent signatories from investing in private markets at scale, in the near term. 

Government response 

While it is clear that the Accord remains a voluntary and so non-legally binding initiative, it is clearly a response to growing pressure, and the not-so-subtle threat of future compulsion. The message from the Government is clear: DC schemes are expected to step up and support the real economy while seeking to improve long-term member outcomes. This was reinforced by the Government’s own press release about the Accord which notably states that “Progress against the commitment will be monitored and the initiative will be reinforced by measures to be announced in the upcoming final report of the Pensions Investment Review” – a clear warning that the Government will be holding a Sword of Damocles over the industry’s collective head regarding the Accord. It does not seem beyond the realms of possibility that the forthcoming Pension Schemes Bill could include a clause reserving the power for Government to mandate about this in the future. 

Other matters 

From a member perspective, the Accord should be a positive development. Private markets – including infrastructure, venture capital, and greener energy – can offer access to new sources of long-term returns that aren’t available in listed markets. If implemented well, this shift could lead to better portfolio diversification, more resilient outcomes, and potentially greater levels of retirement savings for members over time. 

However, private market investing comes with more cost, governance and implementation complexity which all need to be handled carefully. And while the intention to invest in the UK is welcome, concerns remain over whether there is enough investable pipeline to meet these ambitions without compromising on quality or risk. 

Pensions Regulator updates its third-party applications guidance 

The Pensions Regulator has issued updated guidance which sets out what third parties should do if they wish to approach the Regulator to ask it to use one of its many powers, as listed in section 10(6) of the Pensions Act 2004. These powers include appointing an independent trustee and seeking an extension to a deadline for a cash equivalent transfer. The guidance also covers how the Regulator progresses any application, which ultimately must be considered by its Determinations Panel. 

In launching this update the Regulator explains that the guidance helps applicants know what information to supply so that their applications can be assessed as swiftly and effectively as possible. The Regulator also highlights links to two new bespoke application forms. 

PASA examines some dashboard connection difficulties where schemes have more than one administrator 

The Pensions Administration Standards Association has published an online AVC toolkit to help those schemes, in relation to their dashboard connection duties, where they have more than one administrator. Issues can typically arise where AVCs are being administered separately from main scheme benefits and AVC information is being connected to the pensions dashboard central digital architecture directly by the AVC provider. 

PASA makes clear that where a scheme has more than one administrator, including as a result of having a separate AVC provider, achieving compliance will require all providers serving that scheme to connect on the same date. PASA acknowledges that there may be situations where this isn’t achievable and so, despite the best efforts of all parties, a regulatory breach occurs. The toolkit outlines the views of the Pensions Regulator and the Financial Conduct Authority should this situation arise. 

PASA also looks at where due to PDP scheduling, not all ISPs which are associated with one scheme are connected to the ecosystem at that scheme’s staging date, highlighting guidance from the Pensions Regulator as to whether trustees should decide whether to connect the parts/sections of their scheme on a phased basis as ISPs achieve connection. 

PASA concludes by setting out suggested approaches if all administrators are to connect on the same day and then if they are not to all connect on the same day. 

SPP looks at the impact of Trump’s tariffs on pension schemes 

The Society of Pension Professionals has published a short paper exploring the implications of President Trump's tariffs for the UK pensions industry. 

“Trump’s Tariffs and UK Pensions: navigating the fallout” says that whilst those in well-funded DB pension schemes and those who rely on the state pension are likely to be largely unaffected, there could be a significant impact on those in DC schemes, depending on their allocation to growth assets. SPP also states that for local government schemes with significant growth allocations the impact could be significant – and could lead to, for example, higher Council Tax bills – but pensioners from such schemes are unlikely to see any individual impact because their benefits are guaranteed.  

The paper goes on to look at those who are about to retire and those already retired, in both cases focussing its commentary on those with DC savings. 

With an eye to a concern that some with DC savings might panic, amongst the paper’s conclusions are that Government and the pensions industry should remind UK adults that making significant, reactive changes to pensions and other savings generally leads to poor outcomes, compared to cool heads and careful planning. It also says that anyone who is uncertain about their investments and the impact of current events on their pension should seek independent financial advice. 

PDP publishes data protection impact assessment on its central digital architecture and related services 

The Pensions Dashboards Programme has published a data protection impact assessment on its central digital architecture and related services. 

The assessment concerns the processing of personal data by the Money and Pensions Service (MAPs) in accordance with its function to deliver the Pensions Dashboards Programme, building and running the central digital architecture and related services that make pensions dashboards possible, and connecting pension providers, schemes and dashboards to it. 

The MoneyHelper public service pensions dashboard will be covered in a separate assessment.