Transparency data

SAB meeting minutes: 4 July 2024

Updated 10 March 2025

Applies to England and Wales

UK Police Pensions Consultative Forum and Scheme Advisory Board Meeting

42nd Meeting, 4 July 2024, 10:30 – 14:30

Members present:

Independent Chair: Julia Mulligan

Secretariat: Chris Moore

Police Federation of England and Wales (PFEW) – attending as observers:

• Paul Turpin  
• John Partington

Police Superintendents’ Association (PSA):

• Stuart Kehily

Association of Police and Crime Commissioners (APCC):

• Andy Tremayne (SAB Member)

Chief Police Officers’ Staff Association (CPOSA):

Shabir Hussain (SAB Member)

• Gareth Wilson
• National Police Chief’s Council (NPCC)
• Clair Alcock
• Claire Neale
• Kevin Courtney

National Association of Retired Police Officers (NARPO):

• Alan Lees

Home Office (HO):

• Tom Appleyard
• Sara Alderman  
• Simon Primmer

Superintendent’s Association of Northern Ireland (SANI):

• Amanda Ford

Association of Scottish Police Superintendents (ASPS):

• Stewart Carle

Department of Justice, Northern Ireland (DoJNI):

• Antonia Hoskins

Police Service of Northern Ireland (PSNI):

• Stuart Griffin  

Police Federation Northern Ireland (PFNI):

• Damien Walsh

Scottish Police Authority:

• Sharon Dalli
• Alasdair Corfield

Scottish Police Federation (SPF):

• David Kennedy

First Actuarial:

• Craig Moran
• James Allen

Scottish Public Pensions Agency (SPPA):

• Alan Wilkinson 
• Elle O’Kane

XPS:

• David Watkins 
• Kevin Shiel

Welcome and apologies

1. The Chair welcomed James Allen (First Actuarial) Damien Walsh (PFNI) and Stuart Kehily (PSA). Apologies were received from Antonia Hoskins (DoJNI) and Liam Kelly (PFNI).

Minutes of the meeting of 28 March 2024

Action point 1: Secretariat to publish finalised minutes of 28 March 2024 on webpage.

Action log of 28 March 2024

The Chair went through the action log of 28 March 2024, which has been updated in the light of discussion. Key points of all the actions discussed were:

Action point 2: SAB to write to the Home office ahead of 8 October meeting on the possibility of implementing changes regarding the CPI mismatch by April 2026.

2. Shabir Hussain (CPOSA) suggested an enabling regulation without mentioning the date, but as and when we need a data change, it can be done without a need for a regulation.

3. Tom Appleyard (HO) noted they were technically in the pre-election period and were limited in what they could say.

4. Craig Moran (First Actuarial) said a letter should go out, requesting the change and then a suggestion how it could implement it. Shabir Hussain (CPOSA) expressed agreement.

Action point 4: SAB to draft correspondence to scheme managers to address concerns about consistency and promote adherence to the compensation mechanisms guidance for consideration at the 4 July 2024 meeting.

5. The Chair said she would pick up with Clair Alcock (NPCC) and circulate outside of committee.

Action point 5: Clair Alcock (NPCC) to hold a meeting to discuss the pros and cons of early retirement for members leaving after age 55.

6. Clair Alcock (NPCC) said a paper may be written in future work had be delayed due to work on remedy items.

Outstanding from the previous meetings

12 January 2024 - action point 3: SMSG to look at impact on members regarding timing of scheme pays adjustment.

7. Clair Alcock (NPCC) said it was ongoing due to lack of capacity while dealing with remedy items.

12 January 2024 - action point 5: the Chair to hold a meeting with Joanne Livingstone (Fire SAB Chair) on local pension board interaction.

8. The Chair said she would update on the action when it came to the AOB on the future of the SAB.

Remedy implementation – verbal update and discussion, NPCC Pension Team

Clair Alcock (NPCC) provided a presentation on remedy items the NPCC were leading on. The discussion points are highlighted below.  

9. Clair Alcock (NPCC) said that most members are expected to defer payment of their owed contributions until retirement due to the lack of available funds. This was supported by Paul Turpin (PFEW), who noted that anecdotal evidence suggests most members would indeed wait until retirement, although the exact amounts they owe were still unknown.

10. Sharon Dalli (SPA) highlighted the issue of interest accruing on deferred payments until retirement, which might incentivise members to pay earlier to avoid additional interest costs. She pointed out that continuing interest accumulation was a significant factor for members to consider when deciding when to make payments.

11. To improve support and communication with members, Clair Alcock (NPCC) mentioned ongoing enhancements to the police pension website. These improvements aim to help members better understand the remedy process and access updated information more easily. The Chair suggested that tax relief simplification should be included in future communications with the Minister to ensure members are adequately informed.

12. On the topic of tax relief for contributions, Clair Alcock (NPCC) explained the current process and the efforts to push for automatic tax relief application for active members. This change, being considered by HMT, would require ministerial approval post-election.

13. Stuart Kehily (PSA) expressed support for the automatic tax relief application, emphasising that it would simplify the process for members.

14. Clair Alcock (NPCC) indicated the need to continue discussions with HMT regarding interest rate caps and tax relief application. The Chair proposed that the tax relief issues be included in future correspondence with the Minister to advocate for changes that would benefit the members.

Pension dashboard preparation – verbal update and discussion, NPCC Pension Team

Clair Alcock (NPCC) provided a presentation on Pension dashboard preparation. The key points are highlighted below.  

15. Clair Alcock (NPCC) provided an update on the implementation of pension dashboards, noting that all public sector schemes are required to stage for these dashboards by October 31, 2025, with the connection date set for October 31, 2026. She emphasised the critical need for clean and accurate data since members will be able to see their pension details, which is expected to drive significant member engagement and queries. Clair Alcock (NPCC) compared this to the remedy process, highlighting the similar challenges of being time-bound and requiring extensive data accuracy.

16. Survey results shared by Clair Alcock (NPCC) indicated that over 50% of respondents would have started the data preparation process earlier if they had known the scope of the task. She also reported a net promoter score of -56 regarding understanding of the pension dashboards, suggesting that most people are currently unaware or have not considered its implications. Additionally, an net promoter score of -18 was reported for satisfaction with support from local pension boards, indicating governance challenges.

17. Clair Alcock (NPCC) highlighted the necessity of selecting an Integrated Service Provider (ISP) to facilitate the connection to the dashboards. Currently, only 4 out of 12 administrators have selected an ISP, with many yet to start the process. To address these challenges, Clair Alcock (NPCC) said the formation of a working group chaired by an independent industry expert. This group has developed a work plan aimed at ensuring consistent value data across all police pension scheme members.

18. Clair Alcock (NPCC) suggested that the Scheme Advisory Board consider issuing advice to scheme managers through bulletins regarding preparations for the dashboards. She also proposed conducting a survey to track readiness and identify additional indicators for the upcoming year. The urgency of preparing for pension dashboards, addressing data challenges, and ensuring consistent communication and support across the scheme was emphasised.

NI and Scotland update

19. Alan Wilkinson (SPPA) noted similarities to England and Wales regarding the remedy process. He expressed optimism about the resolution for the immediate choice residual service statements, mentioning that processing for 2006 members was expected to begin in August.

20. He reported that Scotland was currently reviewing employer and employee contribution rates due to a 0.24% shortfall identified in the evaluation. They were considering whether to maintain the current flat rate or move to a tiered contribution rate.

21. He also highlighted the focus on progressing work for those excluded from ill-health pensions following the care case. Alan Wilkinson (SPPA) mentioned the possibility of aligning with Northern Ireland by prospectively bringing everyone to the higher contribution rate and addressing the retrospective element on a Four Nations basis. He noted that the issue only impacted about 32 members in Scotland, but action was needed.

22. Stuart Griffin (PSNI) added there was no significant updates to give, but PSNI was working through and trying to understand the implications for their affected members.

Ministerial first 100-day briefing

23. The Chair proposed the creation of a short briefing note for incoming ministers on the Scheme Advisory Board and key issues, supplementing the official briefings from the HO. The Chair highlighted the importance of providing ministers with concise, clear information directly from the bodies involved, despite the complexity of the issues faced.

24. The Chair and Clair Alcock (NPCC) had discussed this idea in a recent meeting, agreeing on its potential usefulness. The note would aim to highlight essential points and be prepared for the main forums under the purview of PABEW and PCF.

25. Tom Appleyard (HO) supported the idea, noting it couldn’t hurt and could potentially elevate the issues on the minister’s agenda. He suggested including the briefing note with his official letter to the minister.

26. The Chair requested assistance from members in preparing the briefing note. She asked members to email bullet points on key issues that should be included. The Chair offered to compile these points and circulate the draft for review and approval out of committee.

Action point 2: SABEW Members to email bullet points on key issues for a briefing note for incoming ministers to PABEW Secretariat mailbox. The Chair to compile and draft the briefing note to circulate to members for review.

Employee Contributions Banding

27. Clair Alcock (NPCC) emphasised the purpose of preparing the SAB to respond to the Home Office consultation on employee contributions. She noted that the goal was to identify important issues and gather key principles for the board’s response. Clair Alcock (NPCC) acknowledged that while the SAB’s focus was on a unified response, members might also consider their other roles, such as within staff associations or representing employers through the NPCC, which might influence their individual responses.

28. Craig Moran (First Actuarial) echoed Clair’s Alcock (NPCC) sentiments and shared his observations from a recent HO meeting, which many participants of the current session also attended. Craig noted the complexity involved, as various models and contribution bands could result in numerous differing opinions. He highlighted the difficulty in reaching a consensus on a single contribution rate due to the diverse perspectives of the bodies represented. He stressed the importance of providing feedback and high-level principles that should guide the contribution rate structure.

29. Craig Moran (First Actuarial) presented slides to illustrate the impact of different contribution rate structures on members. He explained the current tiered contribution system, where higher-paid members contribute more, and contrasted it with a flat rate system.

30. Craig Moran (First Actuarial) pointed out the pros and cons of tiered versus flat rates. He mentioned that tiered rates, where higher earners pay more, are historically justified in final salary schemes as higher earners benefit more. However, he also acknowledged the argument for flat rates, which could simplify the system but might not incentivise pension savings for lower-paid members.

31. Craig Moran (First Actuarial) suggested SAB adopt a set of principles, similar to the approach used by the Fire SAB. These principles could help assess and evaluate any proposed contribution structures more systematically. He concluded by emphasizing that while it might be challenging to agree on specific rates, aligning on guiding principles would provide a coherent and structured response to the Home Office consultation.

32. James Allen (First Actuarial) presented five principles for the SAB to consider in preparing their response to the Home Office consultation on employee contributions. James emphasised that these principles were open for discussion and prioritisation by the board to ensure they align with the members’ views and help evaluate future proposals.

33. He outlined each principle in detail. The first principle focused on protecting lower-paid members, highlighting the importance of maintaining higher contribution rates for higher earners due to their greater tax relief benefits. The approach aimed to encourage lower-paid members to join and remain in the scheme.

34. The second principle addressed the need for uprating contribution bands to keep them aligned with pay grades, preventing the bands from becoming obsolete over time. James Allen (First Actuarial) suggested various measures for uprating, such as aligning bands with pay awards, inflation, or average weekly earnings, while stressing the importance of having any form of uprating in place.

35. The third principle aimed to avoid discouraging career progression by ensuring that promotions do not result in significantly higher contributions that negate the benefits of increased pay. This could involve levelling the gaps between contribution tiers or introducing more tiers with smaller gaps.

36. The fourth principle focused on reducing the risk of opt-outs across the membership. James noted that affordability is a key reason for opt-outs, and emphasised the need for data on why members leave the scheme to better inform decisions.

37. The fifth principle was about ensuring that any changes to contribution structures are simple enough to be administered by all scheme administrators and payroll providers, considering the timeline for implementation.

38. Following James’s presentation, The Chair opened the floor for discussion. Andrew Tremayne (APCC) supported the principles and suggested an overarching principle that contribution bands should contribute to the overall health of the pension scheme and facilitate membership. He emphasized the importance of affordability for lower-paid members to ensure their continued participation.

39. Shabir Hussain (CPOSA) highlighted the need to protect lower-paid members by offering them the option to pay lower contributions for lower benefits, similar to the local government pension scheme. He also stressed the importance of considering the annual allowance’s impact on higher earners and the taxpayer subsidy involved in the scheme. Shabir cautioned against making any changes until the new government’s taxation and pension regime was clear, as impending changes could impact the scheme’s structure.

Regulation wording for payment of lump sum death grants

40. Gareth Wilson (CPOSA) expressed concern on the wording of regulations related to legal representatives in cases where both a member and their spouse die. He emphasised the need for clarity, suggesting that the regulation should state “must” instead of “may” when a legal representative is involved, to avoid misinterpretation. He argued that legally qualified individuals should follow clear guidelines to ensure proper handling of such cases.

41. The Chair then asked for clarification on who should take this issue forward. Gareth Wilson (CPOSA) suggested exploring whether the NPCC had objections and whether the staff associations held a consensus view on the matter.

42. Shabir Hussain (CPOSA) emphasised the need for clear and straightforward procedures, especially during stressful times for families. He argued for removing uncertainties and ensuring that legally qualified representatives can act without unnecessary hoops.

43. Clair Alcock (NPCC) explained that the NPCC’s stance, based on legal advice, was that no change was necessary. She highlighted the need for proportionality in resource allocation, focusing on current pressing issues affecting members rather than potential ones.

44. The Chair concluded the discussion, noting that the NPCC was not prepared to do further work on this issue. Gareth Wilson (CPOSA) agreed to take an action to discuss next steps with other staff associations and provide feedback.

Action point 3: Gareth Wilson (CPOSA) to discuss Regulation wording for payment of lump sum death grants with other staff associations.

Update from XPS, David Walker, Managing Director, XPS

David Walker (XPS) and Kevin Shiel (XPS) provided a presentation on the McCloud Remediation project. Key points are highlighted below.

45. Kevin Shiel (XPS) said 64% of members financial and guard data is complete. Financial data included core financial metrics like pensionable earnings. Guard data included contribution data and related information.

46. While there were data disparities financial data was in a better position with only 7.5% outstanding. 10 forces have not provided complete financial data, with one force having 100% outstanding. 34.94% of guard data is still outstanding.

47. There was continuous engagement with forces to resolve outstanding data issues.

48. Financial and guard data are critical for completing ABS and RSS. Efforts to collect data by end of June have faced challenges, but work continues.

49. On the current data Status for ABS, Financial data accepted from twenty-five forces. Data returned with queries to five forces. Two forces had not provided financial data at all.

50. Ongoing testing with the software supplier to ensure functionality for producing ABS/RSS. Fixes have been deployed, and retesting is underway.

51. Kevin Shiel (XPS) explained the XPS communication Strategy included weekly meetings with NPCC and an oversight board. Regular client meetings, both face-to-face and online, to discuss and collaborate on challenges.

52. Regular updates were published on the website for members. Collaboration with key stakeholders for distribution. There was a commitment to transparent communication, which included updates shared on Facebook.

53. David Watkins (XPS) addressed the progress made in service delivery and identified areas needing improvement. He mentioned the need for better responsiveness in handling complex benefits and issuing quotations. He pointed out that senior officers require more timely information to make informed decisions. He acknowledged the improvements made over the past few weeks and months but stressed that there is still work to be done to enhance the service further.

54. Paul Turpin (PFEW) raised concerns about the timelines for providing retirement options and estimates. He inquired about how far in advance members receive their retirement options and the status of providing future estimates.

55. Kevin Shiel (XPS) responded by explaining the dependency on receiving complete data and the current processing times. He mentioned that estimates were currently provided up to six months in advance, with plans to extend this to 12 months in the future.

NPCC tax resources support / Chiefs Council response on retire and return / NPCC monthly bulletin

56. Clair Alcock (NPCC) said NPCC was working through four modules related to pension resources, including pensions tax, income tax, and how remedy affects these areas. NPPC plan to include examples to help members understand the impacts, especially concerning pensions tax implications from implementing the remedy and how historic annual allowance changes will affect them.

57. Clair Alcock (NPCC) also noted that they are awaiting a firm employer view from Chiefs Council on the issue of retirement return, which should be finalised next week. Initial feedback suggests that reemployment should remain an employer’s decision, not an automatic right for employees. Clair mentioned the recent monthly bulletin and its usefulness for scheme managers and the Scheme Advisory Board.

58. Paul Turpin (PFEW) raised a concern about the inconsistency in the application of the retirement return policy across different forces. He pointed out that while the government suggested retirement return as a solution to the pension trap, if it is not uniformly adopted, it won’t effectively alleviate the issue for many employees.

Any other business - Chair on future of SAB support

59. The Chair told members that herself and Clair Alcock (NPCC) had a meeting last month and they were awaiting a decision from Chiefs Council on a proposal for formal collaboration in the management of pensions. The proposal also included funding for more substantive support for the SAB.

60. The Chair noted the SAB was supposed to provide advice to ministers and have a governance role within the pension framework, which includes working with local pension board which was not being effectively performing at present.

61. To address there would be a questionnaire sent to local pension boards to gauge their awareness of the SAB and gather suggestions for improvement.

62. The Chair explained the importance of determining what data returns the SAB might require for understanding consistency in performance across the sector. She said there was the possibility of setting up a working group and that the results of the upcoming survey could provide valuable insights.

63. The next meeting was scheduled for 8 October 2024.