Responses to consultations
The Board has agreed its response to MHCLG’s closed consultation on the draft statutory guidance accompanying the revised Pooling, Management and Investment of funds and LGPS Amendment regulations. Although a closed consultation, the Board’s response is being shared publicly for transparency with LGPS stakeholders. The Board will also be providing detailed comments directly to MHCLG. The response provides technical comments on each of the draft guidance documents, as well as an overall view on the implementation challenges posed by multiple overlapping reforms. If you would like to discuss this response, please contact the SAB secretariat team.
The Board’s response to the Fit for the Future – technical consultation has been published.
To ensure transparency and to assist Administering Authorities prepare their own responses, the Secretariat had published a draft response prior to final Board approval.
The Board’s response to the Scheme improvements (access and protections) consultation has been published. For this consultation, the Board agreed to endorse much of the response from the Local Government Pensions Committee (LGPC) submitted by Lorraine Bennett. In particular, the Board would like to endorse the technical accuracy of their analysis of the impact of the proposals and how they might best be delivered. The main difference between the Board’s response and that of the LGPC is on the introduction of the Normal Minimum Pension Age and the need for protections for existing scheme members. That difference derives largely from the different composition of the Board, and the advocacy of the member representatives on it.
The Board has submitted a response to The Pensions Regulators enforcement strategy consultation.
The Board is publishing its response to CIPFA’s Code of Practice on Local Authority Financial Reporting in the UK consultation. This annual consultation focusses on the 2026/27 Code of Practice on Local Authority Accounting in the United Kingdom (the Code) which will apply to accounting periods starting on or after 1 April 2026. The Board’s comments are limited to proposals specifically related to the proposed decoupling of local government pension fund accounts from those of their host administering authority. The LGA has made a fuller response, and the Board supports the comments made in that response.
The Board has submitted its response to the Government’s Access and Fairness consultation that was published on 15 May 2025. For this consultation, the Board agreed to adopt the response from the Local Government Pensions Committee (LGPC) submitted by Lorraine Bennett on 29 July 2025. However, the Board has made some additional points on the proposals in it’s own response.
Following publication of the Government’s English Devolution White Paper on 16 December 2024, a consultation was launched setting out proposals for overhauling the local audit system in England. The consultation was called “Local audit reform: a strategy for overhauling the local audit system in England” and closes for responses on 29 January 2025. The consultation set out a strategy to improve the local audit system and included, at paragraph 77, a proposal for decoupling of the pension fund accounts from the main accounts of the administering authority – something which the Board has recommended for some time. The Board welcomed the Government’s commitment set out in this proposal and has sent this response to the consultation
The Board Chair, Cllr Roger Phillips, and Vice-Chair, Jon Richards of Unison, have approved the response that the Board intends to make to the government’s Fit for the future consultation that was published on 14 November 2024. The Board’s response has been shaped by the views of the elected members, scheme member representatives, practitioners and other advisers that sit on the Board. The Board wanted to release this response before the deadline of 16 January 2025 to give administering authorities and other interested scheme stakeholders the opportunity to consider the points raised by the Board when finalising their own responses. The Board hopes the early release of its response is useful for administering authorities and the Secretariat would like to thank all those who contributed for their input. Any comments on this response should be submitted to the Board Secretariat Team at [email protected].
The Board has submitted its response to the Pensions Review Call for Evidence that went out on 4th September 2024. Responses were limited to 500 words per question which made it very challenging to address all of the questions (and the assumptions behind them) which are relevant to the Local Government Pension Scheme. However, the Board Chair, Cllr Roger Phillips, and the Board Secretary, Jo Donnelly, have had face to face meetings with the Local Government Minister, Jim McMahon MP, and the Pensions Minister leading the review, Emma Reynolds MP. We have also been reassured that there will be extensive engagement with the Board and other stakeholders beyond the Call for Evidence itself. Many funds and pools will also have responded to the Call for Evidence or been invited to engagement events directly.
The SAB has issued a short response to the DLUHC consultation on “Addressing the local audit backlog in England“. The consultation was discussed at the Compliance and Reporting Committee when it met on 12th February. The Committee agreed that the Board should express concern that if there were wide-spread disclaiming of LGPS administering authority accounts in order to meet the new deadlines, then there would be knock-on consequences for the 18,000 scheme employers that rely on information from the pension fund audit in order to complete their own audits. Essentially, the scheme employer auditor will need to do further work to gain assurance on the information provided it to it by the LGPS actuary on its assets and liabilities under the scheme, which well may be material, depending on a range of factors. The Board’s response also takes this opportunity to re-emphasise the representations it made in an earlier letter asking that pension fund audit should be separated out from the host authority audit. This would also resolve some of the consequential problems with backlogs as it is not the audit of the pension fund account which is usually holding up completion of the host authority’s audit report.
The Board has today submitted its full response to DLUHC’s consultation on investment issues which opened on 11th July 2023. This consultation included proposals in a range of areas, including; setting a target date for the migration of all listed assets to pools, a proposed move to fewer pools (with a target size of £50bn), a requirement for funds to have a plan to invest up to 5% of assets to support levelling up in the UK and a proposal for funds/pools to dedicate 10% of assets to private equity investments.
The Board’s response was shaped by a working group comprised of elected members, scheme representatives and practitioners from the Board’s membership, led by Board Chair, Cllr Roger Phillips. The Secretariat would like to thank all who contributed to this response for their input. In addition to the above link to the full response, key messages can be found in the story dated 20th September 2023.
SAB has submitted its response to the DLUHC consultation on reforms to the SAB scheme cost assessment process, which closes on 24th March 2023. The SAB scheme cost assessment is the part of the cost management process which operates independently of, and prior to, the HM Treasury directed cost management process. The response is generally supportive of the Department’s approach as they have taken on board many of the points made by the Board on how best to re-align the SAB process with the HM Treasury process, which was reformed last year. We hope that an opportunity will be found to make the necessary amendments to the 2013 LGPS Regulations ahead of the 2020 scheme valuation process being undertaken. The full response can be found here.
SAB has submitted its response to DLUHC’s climate risk reporting consultation, which closes on 24 November 2022. The response includes some over-arching observations on the role of pension funds (as well as their limitations), the production of climate risk reports as well as responses to the Department’s specific questions on governance, scenario analysis, metrics, and risk management. The SAB welcomed the opportunity to engage with the Department’s proposals and believes that pension funds should be able to make a positive contribution by supporting the just transition to a sustainable future. The full response can be found here.
The Board secretariat in consultation with the Investment, Governance and Engagement committee have submitted a response to The Pension Regulator’s consultation on a combined code of practice. The response is available to download using the link below;
The Board at its meeting of the 8 July agreed a response in principle to the above consultation. The Evaluation and Risk Consultation final response (PDF 4 pages 495kb) has now been approved by the Chair and Vice Chair and submitted to MHCLG.
The Board at its meeting of the 8 July noted the Response to HM Treasury consultation on exit payments (PDF 5 pages 271kb) to the HM Treasury consultation on exit payments in the public sector as approved by the Chair and Vice Chair
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