On 6 April, the quality requirements that pension schemes being used for automatic enrolment (“qualifying schemes”) must meet are changing.

DC schemes – what’s changing?

At present, for a DC scheme to be a qualifying scheme:

  • The employer must make a contribution of at least 2% of the worker’s qualifying earnings.
  • The total contributions paid

Superfunds are a hot topic right now in the pensions industry. A consultation on the regulation of superfunds has recently closed, and a response from the Government is expected in the near future. But what are superfunds, and why might they be of interest to an employer with a defined benefit (DB) pension scheme?

What is a “superfund”?

  • A superfund is an occupational pension scheme which will, at a cost, accept a transfer of assets and liabilities from a DB pension scheme.
  • It’s a relatively new concept – there aren’t currently any operational superfunds, although market entrants are actively seeking business.
  • The entity running the superfund will be aiming to make a profit and distribute returns to external investors.  The expectation is that this can be achieved through cost efficiencies, better access to investment opportunities and the pooling of risk.
  • They will be regulated by the Pensions Regulator (although the authorisation framework is not yet in place) and the intention is that they will be eligible for the PPF.


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You may have seen recent – sensationalist – media headlines like:

“’We’re coming for you’ – Amber Rudd’s warning for bosses reckless with employee pensions” (ITV News)
“Reckless bosses who put workers’ pensions in danger could be jailed for seven years” (The Mirror)
Seven-year jail terms unveiled for pension fund mismanagement” (The Guardian)

The

Moses, so we are told, was 120 years old when he died, and “biz hundert un tsvantsik” – [may you live] until 120 – is an old blessing. The joke it gave rise to is probably just as old: Harry is fed up with his noisy neighbour, so he confronts him: “May you live to 119!” he says to his neighbour. “May you live to 120!” he says to his neighbour’s wife. “Why the difference?” asks the neighbour. “After putting up with you, she deserves a year of peace and quiet.” is the reply.

Whilst pension scheme actuaries are not yet assuming that schemes will have 120 year olds, most scheme funding assumes that some pensioners will be receiving their pensions well into their 100s. This is the case even though the latest mortality tables show a slowdown in the rate of increase of longevity.


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The qualifying earnings bands for the purposes of automatic enrolment are due to increase on 6 April 2019. For the tax year 2019/2020, the lower qualifying earnings threshold will be £6,136 (instead of £6,032) and the upper qualifying earnings threshold will be £50,000 (instead of £46,350). The old faithful earnings trigger will continue to remain stable at £10,000.

Why is this important?

Since October 2012, employers have had to make arrangements for certain workers in the UK to be automatically enrolled into a pension scheme that satisfies certain conditions (a qualifying scheme). Very broadly, workers fall into one of three categories (summarised below).


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Employers and trustees who use a guarantee or charge to reduce their pension scheme’s Pension Protection Fund (PPF) levy may need to re-execute that guarantee/charge in order for it to be taken into account in calculating the scheme’s 2019/20 PPF levy.

The PPF provides protection for members of DB pension schemes whose sponsoring employer becomes insolvent. It is funded in part by an annual levy payable by DB pension schemes.


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Welcome to our new blog, “Employer Perspectives”, which is designed to provide practical insights and commentary for UK employers on developments in the employment and pensions industries. Subjects for comment include legislative changes, case law, regulatory developments and wider industry trends that will have a direct impact on UK employers. The contributors are members of