The Pensions Regulator (TPR) should consider a ‘proportionate approach’ to collecting information about well-funded defined benefit (DB) schemes, with the funding regime primarily seen as a compliance exercise rather than a driver of change, according to the Association of Consulting Actuaries (ACA).

Its research of 156 scheme actuaries highlighted that most DB schemes were already well funded and clear on their long-term plans, leaving the funding regime as an administrative task adding to schemes’ workloads.

The ACA therefore called on TPR to urgently simplify its submission for schemes to comply with the statement of strategy requirements.

Almost three quarters (71 per cent) of DB schemes were funded above technical provisions, 61 per cent were above their low-dependency basis, and 35 per cent were above solvency.

The study found that schemes were clear on their endgame plans, but strategies varied.

Over a quarter (27 per cent) were targeting buyout, 31 per cent were planning short-term run-on until ready to buyout, 21 per cent were targeting self-sufficiency, and 10 per cent were actively running on to generate surplus.

Looking at the behavioural impact of the funding regime, around half of respondents highlighted additional documentation as the primary impact, while almost a third cited new expense allowance requirements.

Eight in 10 (80 per cent) DB schemes were found to already satisfy the fast track requirements set out in the funding regime.

The ACA noted that surplus release flexibilities in the Pension Schemes Act 2026 were prompting discussions, especially among larger schemes.

Around a third (34 per cent) of DB schemes had started or expected to start discussions on surplus use.

Nearly a quarter (21 per cent) of schemes over £100m were reviewing or changing endgame strategies, compared to 6 per cent of schemes smaller than £100m.

“Our survey shows that UK pension schemes are generally in a strong funding position and already moving towards their chosen endgame,” said ACA chair, Chintan Gandhi.

“The new funding regime appears to be largely adding to the workload for schemes that are already well managed, rather than driving strategic change. A proportionate approach to capture information on these schemes should therefore be considered by TPR.

“What is more interesting is the emerging impact of surplus reforms, which are starting to shape conversations between pension schemes and employers.

“The devil will be in the detail as the DWP’s regulations and TPR’s associated guidance are formed, and we look forward to continuing our work with industry and policymakers to help shape a clear, workable DB surplus release regime which properly balances the release of surplus with adequate clarity and confidence for employers, appropriate safeguards to members’ benefits, and aligns appropriately with trustees’ duties.”

---