LawDebenture has called for changes to the Financial Conduct Authority’s latest proposals for the Value for Money Framework, supporting the overall direction of the reforms while raising concerns about how amber ratings could affect workplace pension arrangements.
The FCA, Department for Work and Pensions and The Pensions Regulator published the latest joint consultation, CP26/25, on 13 July 2026. The consultation builds on proposals first published in 2024 and further changes put forward earlier in 2026.
Elizabeth Hartree, Director and Head of Defined Contribution at LawDebenture, said the company supports several of the changes made during the consultation process. These include simplifying backward-looking metrics, removing the requirement for external advice when assessing forward-looking metrics and introducing a bedding-in period during which ratings would not automatically trigger consequences.
LawDebenture’s main concern relates to arrangements that receive an amber rating. The company argues that an amber rating could create commercial pressure that ultimately leads to an arrangement being closed to new business, even where the underlying issues could be addressed.
Under the proposed framework, an amber rating could affect how employers, advisers and other market participants view a pension arrangement. LawDebenture says this could create a situation in which employers move away from a scheme and advisers become less willing to recommend it, potentially reducing the funds available to the arrangement.
The company is therefore calling for a defined cure period. This would give trustees time to demonstrate that identified issues can be addressed and that an arrangement has a route back to a green rating before market reactions determine its future.
Law Debenture Corporation plc (LON:LWDB) provides a wider range of services including corporate and pension trusts, process agent services, treasury management, corporate services including for special purpose vehicles, structured finance administration and whistleblowing services.
