Scottish pensions

Scottish pensions compared with the rest of the UK

There are relatively few differences in the general structure of pension schemes in Scotland, as compared with the rest of the UK.

As in England, the vast majority of final salary occupational pension schemes in Scotland are:

  1. set up under trust and governed by a trust deed and rules, which are amended over the years as legislation and benefit provision change. In most cases, amendments were, in the past, carried out by administrators and providers. However the increasing complexity and burden of pensions legislation and regulation has seen this kind of work transferred over the years to specialist pensions lawyers

  2. subject to volatility and high costs. This has led to the widespread closure of defined benefit schemes across Scotland, and much of the work carried out day-to-day by pensions lawyers working on Scottish schemes would be familiar to those who work solely on English schemes, with an increased focus on liability reduction and de-risking initiatives. Sadly, the continued squeeze on employers has resulted in a significant amount of financial distress for both employers and schemes which, in many cases, has

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Joint regulatory VFM proposals aim to improve transparency and comparability in DC pension schemes

The Pensions Regulator (TPR) and the Financial Conduct Authority (FCA) have published a joint regulatory consultation and consultation response in CP26/1 setting out how a new value for money (VFM) framework could operate consistently across defined contribution (DC) workplace pensions. The proposals are designed to move the industry away from narrow cost-based assessments and towards a more holistic and comparable evaluation of the value delivered to pension savers in both trust-based and contract-based schemes. The proposed framework is intended to enable trustees, providers and governance bodies to assess the long-term performance of DC pension schemes for savers, improving transparency and competition by making it clearer which schemes deliver good value, and which do not, and supporting better retirement outcomes. The FCA has also published its response to feedback on its earlier consultation CP24/16 and the new consultation on revised detailed rules and guidance for contract-based schemes are to be implemented through the FCA Handbook. For trust-based schemes, where the Department for Work and Pensions (DWP) will legislate for the framework through the Pension Schemes Bill currently before Parliament, CP26/1 serves as discussion paper intended to gather timely input from the industry to help shape the detailed regulations and guidance that DWP and TPR are set to develop. The deadline for responding to consultation CP26/1 is 8 March 2026.

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