UK Pensions: What’s new this week? May 19, 2025

Mansion House Accord: pension providers commit to increase private investment

Seventeen pension providers have signed up to the Mansion House Accord: a voluntary, non-binding initiative setting an ambition to invest a minimum of 10% of main DC default funds in private markets (equities, property, infrastructure and debt/credit) by 2030. At least 5% should be invested in UK private markets (that is, where the underlying assets are based in the UK). The ambition refers to an aggregate level of investment across all in-scope funds. The Accord makes it clear that this is subject to trustees’ fiduciary duties and the Consumer Duty (for FCAregulated providers). It also lists a number of government actions that are critical to enabling the commitments, such as facilitating a pipeline of UK investment opportunities and successfully delivering the upcoming Value for Money framework.

The Mansion House Accord is separate to, but builds on, the 2023 Mansion House Compact. Signatories to the Compact set the ambition of allocating at least 5% of DC default funds to unlisted equities by 2030. For those providers signed up to both, investments in the scope of the Compact contribute to the Accord.

Read the Mansion House Accord, FAQs and the government’s press release.

Dashboards: PDP publishes data protection impact assessment and progress report

The Pensions Dashboards Programme (PDP) has published a data protection impact assessment (DPIA) for the processing of personal data by the Money and Pensions Service (MaPS) in relation to the central dashboards architecture. MaPS' provision of the MoneyHelper public service pensions dashboard will be covered in a separate DPIA.

A DPIA is a process intended to help data controllers systematically analyse, identify and minimise the data protection risks in relation to ‘high risk’ processing operations (which include matching data from multiple sources—an essential component of dashboard-related processing activities). The PDP DPIA echoes previous messaging from the Information Commissioner’s Office (ICO) that pension schemes are responsible for putting in place their own DPIAs in respect of dashboards data processing. Some information in the PDP DPIA may be helpful for schemes completing their own DPIAs. If you would like help with your scheme’s DPIA, please contact your usual A&O Shearman adviser.

Read the PDP DPIA.

The PDP has also published its latest progress update report. The report discusses connection of the first schemes and providers to the dashboards ecosystem and timelines for user testing. It reiterates the ‘pragmatic approach’ being taken by TPR and the FCA in relation to compliance with connection deadlines, noting ‘both regulators have been clear there will be no regulatory intervention for pension providers and schemes who are unable to meet their ‘connect by’ dates in guidance solely due to their dependence on an industry participant who has yet to connect’.

The PDP is confident that all pension providers and schemes in scope will be able to connect by the regulatory deadline of October 31, 2026.

Read the progress update report.

Research on value for money in decumulation

A research report sponsored by the Pensions Regulator (TPR) has been published, looking at challenges to value for money in DC decumulation. Some of the findings include:

• That two ‘defaults’ have emerged in the way that savers use their DC pots: full cash withdrawals and passive continuation in accumulation strategies, both of which may be misaligned with long-term retirement needs.
• That many savers, especially those with smaller pots, make decisions without support.
• That regulatory uncertainty around the boundary for regulated advice limits the help schemes and providers feel able to give.

Commenting on the report, TPR refers to the existing plans for a guided retirement duty (requiring schemes to offer decumulation services) to be included in the upcoming Pension Schemes Bill, saying that this presents ‘a fantastic opportunity for industry and policymakers to provide products and services suitable for different kinds of savers’. It also links current initiatives in relation to data and innovation to helping to improve decumulation offerings. TPR will continue to work with the FCA on its review of the boundary between advice and guidance.

Read TPR’s press release and the research report.