The Association of Consulting Actuaries is calling on the Pensions Regulator to “urgently” simplify how schemes must comply with statement of strategy requirements. The request comes as conversations between trustees and employers are starting to be around surplus.

Defined benefit schemes see the new funding regime primarily as a compliance exercise, the ACA said. The association surveyed 156 scheme actuaries, finding that schemes are largely progressing towards their chosen endgame strategies. The new funding regime is seen as “administrative rather than transformative”, it said, with additional documentation being the main change, along with new expense allowance requirements.  

The actuaries association wants to see these requirements to be made less onerous. “The new funding regime appears to be largely adding to the workload for schemes that are already well managed, rather than driving strategic change. A proportionate approach to capture information on these schemes should therefore be considered by TPR,” said ACA chair Chintan Gandhi.  

Most schemes already meet expectations, with the survey suggesting that four-fifths comply with the regulator’s Fast Track requirements.  

Future behaviour might be shaped more by surplus policies than the funding regime, the association suggested – a third (34%) of schemes have started or expect to start discussions on surplus use. 

Surplus reforms are starting to shape conversations between pension schemes and employers, said Gandhi, but he believes “the devil will be in the detail” of the Department for Work and Pensions’ regulations and TPR’s guidance.  

Other survey findings include that 27% of schemes are targeting buyout, 31% are planning short-term run-on until they are ready to buy out, 21% target self-sufficiency and 10% are actively running on to generate surplus. 

About a fifth of schemes over £100m are reviewing or changing endgame strategies, compared with just 6% of schemes smaller than £100m, according to the ACA. 

A separate survey by consultancy Barnett Waddingham found that among medium-sized schemes, 35% have moved from self-sufficiency to run-on, and two-thirds (67%) of large schemes have switched endgame from buyout to self-sufficiency.  

It also suggests that 62% of DB trustees would be more likely to consider run-on strategies under the Pension Schemes Act 2026. However, they felt that there is government pressure to use surpluses “in ways that might conflict with fiduciary duties”. 

Managing partner at Barnett Waddingham, Alex Pocock, said the debate around surplus use is a natural consequence of the fact most schemes that wanted to buy out have done so by now. 

“Trustees will recognise the opportunities that surplus capital can create, but our findings show that they’re also firmly focused on their responsibilities to act in members’ best interests,” he said.
 
Pocock argued that use of surplus does not have to come at the expense of member outcomes. “The recent surplus proposals are a positive step forward, but trustees will still need the confidence to make use of these new flexibilities while remaining aligned with their fiduciary duties. As more schemes weigh up these options, balancing member, sponsor and trustee interests will be critical,” he noted.