Most major defined contribution (DC) pension providers are not currently meeting the £25bn minimum scale requirement set out under the Pension Schemes Act 2026, Hymans Robertson has found, with only seven of the 16 providers analysed above the threshold .

The consultancy’s latest DC Provider Insights report found that, as of 31 March 2026, a further three providers met the £10bn transition pathway threshold.

Under the act, master trusts and group personal pension (GPP) providers will need to demonstrate that their main scale default arrangement either exceeds £25bn in assets by 2030, or is on a plausible path to reaching the threshold by 2035, with at least £10bn by 2030.

However, Hymans Robertson noted that the definition of qualifying assets for the scale test remains unclear, with some providers expected to cite broader asset pools, which could increase reported assets under management or enable them to meet the scale requirements through other measures.

The research also revealed that members had seen positive returns across all stages of the retirement journey over the five years to 31 March 2026, although there were significant differences across the provider market.

For younger members, Hymans Robertson said historic conservative positioning, differences in portfolio construction and regional differences in equity exposure had driven around a 7 percentage point annualised gap between the best and worst performers.

The consultancy noted that performance over the period was heavily influenced by the extent and form of exposure to the listed equity market, despite periods of significant volatility.

It said this was also evident in later stages of the glidepath, where differences in risk appetite and approaches to credit had contributed to wide variation in outcomes.

The report also warned that intra-day volatility had a meaningful impact on reported performance at the end of Q1 2026, as fast-moving geopolitical developments affected reported returns depending on the time of day underlying funds were priced.

The firm argued that past performance supported the trend towards maintaining higher-risk strategies for longer, although concentration risk and policy volatility remained important considerations.

It added that strategy construction and resilience would have an “outsized impact” on retirement adequacy, with members feeling the impact of investment decisions over the long term.

Meanwhile, looking at projected member outcomes, Hymans Robertson said the range of projected outcomes continued to vary widely across the market at every stage of the retirement journey.

While median projected outcomes for younger members have broadly converged as most providers have adopted higher-risk strategies, the report found that clearer differences emerge at later stages of the glidepath.

It noted that allocations to private assets are now appearing across a wider range of providers’ strategic asset allocations, contributing to some upside differences in projected outcomes.

However, Hymans Robertson cautioned that “extreme care” is needed around strategy design and implementation, as well as manager and deal selection.

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