The High Court’s decision in the Lloyds Bank case:

  • requires schemes to equalise benefits earned in the period between 17 May 1990 and 05 April 1997 to correct for the inequalities of GMPs
  • approved a range of methods that could be adopted to achieve that requirement

However, given the complexity of the subject, the Lloyds Bank case couldn’t deal with all issues which can arise in an equalisation project.

In this context:

  • DWP has published guidance on the use of GMP conversion legislation to equalise for GMPs
  • PASA has published Guidance outlining methods, including GMP conversion, which schemes could use to correct for the inequalities of GMPs, highlighting certain issues with current legislation and guidance
  • HMRC has published two newsletters providing guidance on the tax issues relating to equalising for GMPs but said it isn’t currently in a position to provide any supplementary guidance on conversion

Most schemes will want to implement GMP equalisation projects as soon as reasonably practicable. Many will wish to do so using GMP conversion (method D2 in the Lloyds Bank case). This Guidance has been prepared to help show how they might do so in a proportionate and pragmatic way in the absence (at the time of writing) of further guidance or legislation from DWP and HMRC. It outlines approaches to the application of GMP conversion the authors are aware either have been adopted or are actively being considered by early adopters, together with associated considerations. It isn’t intended to advocate a particular course of action.


July 2021 – GMPE Conversion Guidance


July 2021 – GMPE Conversion Guidance launch webinar


Alasdair Mayes (Chair) (LCP)

Anna Rogers (Arc Pensions Law LLP)

Bill Mexson (Siemens plc)

Chris Widdison (Travers Smith LLP)

Duncan Buchanan (Hogan Lovells LLP)

Evey Tang (ABI)

Glyn Bradley (Mercer)

John Wilson (Spence & Partners LLP)

Julian Tolan (Capita)

Lisa Hayes (XPS Group plc)

Lynda Whitney (Aon)

Marc Bergen (BT Group plc)

Matthew Davis (Hymans Robertson)

Simon Pariser (Willis Towers Watson)

Stephen Scholefield (Pinsent Masons LLP)

Steve Nicholson (Equiniti)