Draft Occupational Pension Schemes Regulations 2023 consultation – our response

The NHF has responded to the Department for Work and Pensions consultation on the Draft Occupational Pension Schemes (Funding and Investment Strategy and Amendment) Regulations 2023.

The consultation invited feedback on proposed new requirements for pension schemes to have a funding and investment strategy and submit a statement of strategy to the Pensions Regulator.

In our response we propose that Department for Work and Pensions, and the finalised Regulations, allow the Pensions Regulator to:

• Recognise the minimal risk of default from housing associations.
• Formally recognise the significantly longer covenant visibility and resilience to risk of housing associations and convert this into suitable funding parameters.
• Understand the significant impact on the development of new housing and the UK’s net zero commitments that requiring more money to be directed into pension schemes sooner would have.
• Have a clear approach internally to dealing with schemes sponsored by housing associations to ensure that a consistent approach is taken.
• Enable trustees to have clear guidance that schemes sponsored by our members can work within the principles agreed for housing employers, to enable consistency and efficiency for both the Pensions Regulator and individual housing associations.

The consultation closed on 17 October. If you’d like any further information on the proposals or our response, please get in touch.