Led by the Trustee, Railpen works hard to advocate for your scheme and its members. We work closely with the UK government and regulators at all levels, representing members’ interests as key legislation and policy is developed.

A major area of focus at the moment is the Pension Schemes Bill (the Bill), proposed legislation to significantly reform the UK pension system.

The Bill focuses on consolidating smaller pension pots, improving the value for money and security of pensions, and increasing investment in the UK economy. The Bill also aims to introduce some helpful flexibilities for defined benefit (DB) schemes and legislates for a regulatory framework for DB Superfunds.

It’s a Bill that’s high up on the Government’s agenda, and – because of what it could mean for members and employers – it’s high on ours too.

Railpen analysis: welcome reform, with room for improvement

Overall, we welcome the objectives of the Pension Schemes Bill.

We share the Government’s commitment to ensuring that the Bill improves returns for savers, prioritises value, and drives long-term UK investment and growth. Within it, there are some provisions that we specifically endorse.

In particular, we welcome:

• Removal of restrictions on the Pension Protection Fund (PPF) to allow it to charge a zero levy: the Trustee and Railpen have been lobbying on this for some time and on 23 September the PPF announced that it was now sufficiently comfortable with the draft Bill to reduce this year’s levy to zero. The PPF had proposed to charge schemes £45m, so this is a fantastic outcome, saving the railways pension schemes an estimated £11m this year alone. We’ll continue engaging to influence, to ensure the best outcomes for the schemes and their members.

   

• Value for Money Framework: from a defined contribution (DC) perspective, the Bill sets out the high-level elements of this Framework, aiming to increase scrutiny and competition on long-term scheme value rather than cost. We’ll continue engaging with Government as we await the supporting regulations, which must ensure the industry can meet its requirements in an expedient, proportionate way.
  

However, there are also areas where we have concerns.

Specifically, the Bill introduces a so-called ‘backstop power’, which would essentially allow the Government to mandate investment in certain types of assets, specifically in the UK. While the Pensions Minister has insisted that this provision won’t be used, we remain opposed to it being enshrined in legislation.

Aside from the fact that Railpen has invested in the UK for decades – with around a third of our assets currently invested in our domestic economy – trustees have a fiduciary duty to act in the best interests of their members.

So, while we see building a strong and vibrant UK economy as an impactful and vital way to secure our members’ future, we must invest in a way that best aligns with scheme and section characteristics and objectives. It would be wholly inappropriate, and introduce great risk into the pension system, if the Government were to consider any form of mandation towards UK investments.

That’s why we’re constructively engaging with various government departments to try and shift the focus to removing barriers to investment rather than mandation. (We talked about this at our Pension & Investment Conference in May this year – to find out more, click here.)

Advocating for members

Many of the policies that the Bill seeks to introduce have been signposted and tested with the industry for some time, and we’ve engaged extensively as the detail of these policies has been developed. To ensure that any remaining concerns are considered before the Bill becomes law, we’ve launched a robust outreach campaign, highlighting our proposals and recommendations to key decision-makers.

Following our initial response to the Pension Schemes Bill Committee’s call for evidence in August, we’ve also written to the Pensions Minister, the Committee members, the Chair of the Pensions & Growth All Party Parliamentary Group (APPG) Sarah Edwards MP, and member of the Pensions Commission Baroness Drake (amongst other Peers in the House of Lords).

So far, the response from all parliamentarians has been extremely positive, and Railpen has had several constructive engagements. Particularly noteworthy was a reassuring response from the Pensions Minister, which opened up a dialogue to continue discussions and relay feedback on behalf of members.

Next steps

Now that the Bill has reached the end of its House of Commons Committee Stage, it will undergo its Report Stage in the Commons before moving across to the House of Lords for further scrutiny. We’ll then have another opportunity to advocate for our members by engaging with legislators in the Lords. We will continue to express our support for the Bill’s intentions whilst ensuring that any remaining concerns we may have are raised at this crucial stage.  

The final version of the Bill is expected to receive Royal Assent – in other words become law – in 2026.

For more information about the Pension Schemes Bill, head to page 2 in our Pension News Update for Q3 2025.