PASA welcomes the opportunity to respond to CP25/17 and share insights from occupational pension schemes. We aim to ensure targeted support proposals work in practice and deliver meaningful outcomes for savers.
Scope and Segmentation
Savers in occupational schemes often fall outside FCA regulation, and segmenting them effectively is complex. We urge the FCA to recognise the diversity of scheme structures and avoid assumptions based on retail models. It’s important the FCA continues to collaborate with the DWP for these reasons.
Schemes may not hold the same data as providers. This limits their ability to deliver targeted support without disproportionate effort. We recommend a flexible framework which reflects these operational realities.
Care needs to be taken where consumers have benefits in hybrid pension schemes, where a significant proportion of a consumer’s benefits are defined benefit and guidance focused solely on defined contribution benefits could be misleading.
Boundaries of Support
Schemes have long struggled with the boundary between ‘guidance’ and ‘regulated advice’. A third strand will make this more complex. Schemes need clear boundaries and confidence guidance won’t expose them to regulatory risk.
We support the development of tools to help savers make informed decisions. However, these tools must be proportionate, accessible, and designed with scheme capabilities in mind.
Delivery and Practicality
Schemes are well placed to deliver targeted support, but they need clarity, confidence, and collaboration. We encourage the FCA to work with industry bodies to co-design practical solutions.
Targeted support should be actionable and easy to understand, especially for savers with limited financial literacy.
Conclusion
We’re committed to supporting the FCA’s goals and ensuring targeted support works for all savers. We welcome further engagement and stand ready to collaborate on next steps.
Check out the Consultation response here: PASA Consultation response – FCA consumers pensions and investment decisions – proposals for targeted support
