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Consultation responses

09 March 2026

FCA Consultation CP24/16: The Value for Money Framework

The Pensions Management Institute (PMI) welcomes the opportunity to respond to the FCA’s consultation on the proposed Value for Money (VFM) framework for workplace defined contribution (DC) pension schemes. As the UK’s leading professional body for pensions, representing trustees, governance committees, providers, advisers, and administrators, the PMI supports the ambition to improve outcomes for savers and strengthen confidence in the DC system.


We recognise the significant joint work undertaken by the FCA, DWP and TPR to develop a coherent, market-wide framework. A consistent, comparable approach to the VFM assessment has the potential to drive better long-term outcomes, support consolidation where appropriate, and enhance transparency for those overseeing schemes. Our response focuses on proportionality, practical implementation, and the need to ensure that the framework supports - not inadvertently constrains - innovation, effective investment strategies, and good governance.

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