Pensions Bulletin 2025/24
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This edition: Nausicaa Delfas blogs again, Fraud compensation levy set for 2025/26, Pension Fund clearing exemption regulations made and Clara breaks new ground with covenant-retaining transaction.

Nausicaa Delfas blogs again
In the latest blog from the Pensions Regulator, Chief Executive Nausicaa Delfas uses broad brush strokes to talk about the impact of the Pension Schemes Bill, how the Regulator is working “to address unfinished business in the pensions system”, and why the pensions industry must push for ever higher standards “to help unlock transformational opportunities”.
Of particular interest is her expectation, under the “Innovation” heading, that DB trustees should “have plans ready for how they would respond to sponsoring employers’ requests to release some of their scheme’s surplus”. This chimes with the wording contained within the Regulator’s new models and options guidance published earlier this month (see Pensions Bulletin 2025/22), albeit perhaps less formal. The guidance stated that it was “good governance practice to have a policy on surplus extraction appropriate to the context of the individual scheme”, suggesting that a policy should be drawn up including details of how members and the employer are likely to benefit from the release, so that trustees were ready for any surplus distribution proposal.
Also mentioned under the same “Innovation” heading was the Regulator’s recently launched innovation support service. And in a later blog its Head of Innovation and Design Practice recounted what appears to have been a successful launch event.
Comment
The Regulator (and Government’s) recent focus on surplus release is a clear signal that we are living in changed times. Not so long ago, it was very much the exception for a DB scheme to be running a surplus at a sufficient level that it could contemplate releasing some of it.
Fraud compensation levy set for 2025/26
The Pension Protection Fund has announced that the Fraud Compensation Fund levy for 2025/26 will remain at the same level as in 2024/25, which is the highest amount currently permitted. Therefore, the 2025/26 levy is £0.65 per member for authorised master trusts and £1.80 per member for other eligible occupational pension schemes. This levy is collected by the Pensions Regulator on behalf of the Fund.
The announcement also states that since November 2020, the Fund has paid out £136.2m in compensation to 64 schemes. There are a further 66 claims in the pipeline with a potential value of £326.6m and they are aware of at least 37 further claims with a value of approximately £85m.
Comment
The total expected bill for post November 2020 payments continues to rise with another £80m or so being added in the past 12 months. This may put into doubt the DWP’s intention that the Fund would be back in balance by around 2030, with the DWP loan paid off as a result of the higher levies that have applied since the 2022/23 financial year. We look forward to reading the Fund’s annual report for the year ending 31 March 2025 which must be due for publication soon.
Pension Fund clearing exemption regulations made
The Government has made regulations so that the current temporary exemption that pension funds based in the UK have from the obligation to clear certain derivatives contracts at a central counterparty continues to operate beyond its 18 June 2025 cut off. This follows a decision announced in January 2025 (see Pensions Bulletin 2025/02).
The Pension Fund Clearing Obligation Exemption (Amendment) Regulations 2025 (SI 2025/670) came into force on 11 June 2025 and makes permanent the above exemption.
Comment
The clearing obligation emanates from EU law and a similar temporary exemption applied within the EU from which the UK benefited whilst it was inside the bloc. However, this EU-wide exemption came to an end on 18 June 2023 and as a result, EU pension funds with a derivative position above a certain threshold have been required to clear certain derivative contracts through central counterparty clearing for the past two years.
Clara breaks new ground with covenant-retaining transaction
Clara, the sole DB superfund that is currently able to transact business, has announced its fourth transaction – the first such deal in the charitable sector and also the first to retain a link back to the sponsor, Church Mission Society.
As a consequence of this “Connected Covenant” transaction of £55m – the smallest Clara has made to date – the Church Mission Society Pension Scheme will not only benefit from similar protections to previous DB Superfund transfers but also retain access to the existing sponsor in the event that additional support should be needed.
Comment
In noting this latest deal, LCP partner Jonathan Griffith points to a recent LCP webinar in which nearly half of attendees said that the a DB Superfund is potentially appropriate for their scheme, whilst LCP partner Richard Soldan said that the deal makes clear that a DB superfund is an option that charities and their pension schemes will want to consider carefully.
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