On 13 July 2026, the DWP and the FCA published an updated consultation on a Value for Money framework for workplace pension schemes, focused initially on default and quasi-default defined contribution arrangements. It’s built around comparing schemes on cost, investment performance and service quality together, rather than cost alone. The consultation closes on 1 September 2026, with the FCA expecting the first larger schemes to complete assessments from 2028, and broader rollout from 2029.
My first reaction was that this felt like a workplace pensions story, not an advice story. It largely still is. The framework is aimed at scheme operators, trustees, independent governance committees and employers, not at individual advice recommendations. But the more conversations I’ve had about it, the more I think the information it eventually produces is worth advisers keeping an eye on.
CP26/25: The Value for Money Framework: consultation
Why this might still matter to advisers
Cost has always been a relatively easy thing to justify in a suitability report. It’s a number. Either the charges are competitive or they’re not, and that’s simple to evidence. Value is a different kind of judgement, made up of things that are harder to reduce to a single figure: how a scheme’s investments have actually performed, how responsive the provider is, whether members get the support they need when something goes wrong.
The framework is not an adviser suitability rule, and it does not automatically mean a scheme with a weaker rating is unsuitable for an individual client. But once more comparable value information exists across workplace schemes, it may become another piece of evidence firms need to consider and interpret, particularly where a workplace or legacy arrangement forms part of a wider recommendation.
That’s the interesting part, for me. Not a new rule, but a new source of evidence that didn’t really exist in this form before.
What’s worth doing now
- Start noting the reasoning behind scheme and provider recommendations in more than cost terms, even informally, so there’s a trail to point back to later.
- If your firm runs a centralised retirement or investment proposition, take a proper look at how each element would hold up against cost, performance and service, not cost alone.
- Keep half an eye on how the framework’s ratings actually get published as it rolls out from 2028 onward. A scheme that looks fine today could be rated differently once the comparisons exist.
- Consider how your research and review processes would use future published value assessments where a client’s workplace or legacy arrangement is relevant to the advice.
None of this is about second-guessing recommendations that have already been made, or assuming every legacy scheme needs revisiting because of this consultation. It’s about building the habit of capturing why a scheme was considered good value at the time, so that reasoning is there if it’s ever needed.
The framework is primarily a workplace pensions reform, still some years from full rollout. But the information it creates could eventually influence research, review processes and the way firms evidence decisions involving existing workplace arrangements, even without becoming a suitability rule in its own right.
As these value ratings start to appear over the next few years, what would you want to see change first in how your firm researches workplace schemes?
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