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:

ACA responds to consultation on trusteeship and governance

We have submitted a response to the Department for Work and Pensions consultation on trusteeship and governance in trust-based pension schemes. We say that the current system largely functions well, with the majority of large schemes operating effectively, whilst outlining Read More ... more »»

11th February 2026 David Robertson

ACA responds to TPR consultation on Extending the CDC code of practice

We welcome the draft code of practice and are generally supportive of the content, and the objective of having the final code in force on the same day as the unconnected employer legislation comes into force, in July. More… more »»

6th February 20267th February 2026 David Robertson

ACA response to FCA consultation CP25-39 – Changing pensions market

We responded to the FCA paper on the changing pensions market as follows: more »»

We responded to the FCA paper on the changing pensions market as follows:

5th February 20262nd June 2026 David Robertson

ACA responds to Inheritance Tax on pensions: Finance (No.2 Bill) 2024-26

We responded to the clauses published in Finance (No 2) Bill 2024-26 to implement the Government’s policy to bring unused pensions funds and death benefits within the scope of inheritance tax (IHT) as follows: more »»

30th December 2025 David Robertson

Response to PPF 2026/7 Levy consultation

We have responded to the online PPF 2026-27 Levy consultation as follows: more »»

We have responded to the online PPF 2026-27 Levy consultation as follows:

5th December 20256th December 2025 David Robertson

ACA response to Post-Implementation Review of TCFD Disclosure Regs

Find below our response to the DWP Post-Implementation Review of Task Force on Climate-related Financial Disclosure Regs, more… more »»

Find below our response to the DWP Post-Implementation Review of Task Force on Climate-related Financial Disclosure Regs, more…

2nd December 2025 David Robertson

ACA responds to DWP Retirement Collective Defined Contribution consultation

We strongly supports the development of the legislation required to enable Retirement CDC pension schemes. We agree that this will open up CDC pensions to a much wider range of people, providing significant advantages over many existing forms of ‘at Read More ... more »»

1st December 2025 David Robertson

ACA responds to FRC’s AS TM1 : Statutory Money Purchase Illustrations

We have responded to the FRC’s AS TMI: Statutory Money Purchase Illustrations consultation making a number of suggestions as follows: more »»

We have responded to the FRC’s AS TMI: Statutory Money Purchase Illustrations consultation making a number of suggestions as follows:

7th October 202511th October 2025 David Robertson

ACA evidence to House of Lords Committee on Reforming IHT – pension funds and death benefits

We provided evidence to the House of Lords Finance Bill Sub-Committee: Call for evidence: Reforming inheritance tax: unused pension funds and death benefits as follows: more »»

We provided evidence to the House of Lords Finance Bill Sub-Committee: Call for evidence: Reforming inheritance tax: unused pension funds and death benefits as follows:

17th September 202522nd September 2025 David Robertson