Consultation Responses

Please find below links to Association responses to consultations conducted by Government Departments and other bodies. Providing input and comment on public policy and topical issues is one of the principal roles of the Association. These responses to a wide range of government departments, regulatory and other bodies are archived below in date order:

Response to FRC call for feedback on Technical Actuarial Standards

See below our comments on the FRC’s Call for Feedback on the Technical Actuarial Standards… more »»

See below our comments on the FRC’s Call for Feedback on the Technical Actuarial Standards…

23rd April 2021 David Robertson

ACA response to Strengthening the Pensions Regulator’s Powers: Contribution Notice and Information Gathering Powers Regulations 2021

We have responded to the DWP consultation as below: more »»

We have responded to the DWP consultation as below:

22nd April 202122nd April 2021 David Robertson

ACA responds to Implementation of the change in Normal Minimum Pension Age consultation

We have responded to the consultation expressing a number of concerns, see more »»

We have responded to the consultation expressing a number of concerns, see

21st April 2021 David Robertson

ACA critical of lack of clarity in TPR Criminal Offences draft guidance

In our response to the TPR’s consultation on the investigation and prosecution of the new criminal offences guidance, we express agreement with TPR’s high-level policy intent, but more clarity needs to be added to the details of the policy, given Read More ... more »»

15th April 2021 David Robertson

ACA responds to Incorporating Performance Fees Within the Charge Cap

We have responded to the DWP consultation on Incorporating Performance Fees within the Charge Cap noting a number of concerns… more »»

We have responded to the DWP consultation on Incorporating Performance Fees within the Charge Cap noting a number of concerns…

14th April 2021 David Robertson

ACA expresses support in OTS response for ‘sensible’ initiatives to simplify pension tax system

In our response to the Office of Tax Simplification’s call for evidence on its third-party data reporting review, we expressed support for any ‘sensible’ initiatives to simplify the processes of the pensions tax system and make it easier for individuals Read More ... more »»

10th March 2021 David Robertson

ACA response to Taking action on climate risk: improving governance and reporting by occupational pension schemes,

In our response to the DWP consultation we welcomed the DWP’s response to practical issues identified in its previous paper but stress the huge changes for trustees addressing this issue and the risks involved with ‘spurious data gathering and calculations’ Read More ... more »»

27th January 2021 David Robertson

ACA response to General Levy consultation

In our view, there should be an opportunity for industry scrutiny of whether the regulatory activities paid for by the general levy represent adequate value for money. We would argue that levy payers deserve some role in this process, to Read More ... more »»

7th January 2021 David Robertson

ACA responds to APS P1 review

We are in favour of the revised version and welcome the streamlining and clarity. We have a few areas where we think the drafting as stands might result in unintended consequences and these are set out in our response, see more »»

17th December 2020 David Robertson

ACA responds to TPR strategy paper

We broadly agree with the strategic priorities set out in the document. Whilst we agree that TPR should continue to increase its oversight of DC pension savings, we envisage that DB pensions will continue to require significant regulatory oversight for Read More ... more »»