Transparency data

SAB meeting minutes: 8 October 2024

Updated 10 March 2025

Applies to England and Wales

UK Police Pensions Consultative Forum and Scheme Advisory Board Meeting

43rd meeting, 8 October 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 

Police Superintendents’ Association (PSA):

• Dan Murphy

• Stuart Kehily

Chief Police Officers’ Staff Association (CPOSA):

• Shabir Hussain  

• Gareth Wilson

National Police Chief’s Council (NPCC):

• Clair Alcock

• Claire Neale

• Kevin Courtney

Home Office (HO):

• Helen Fisher

• Sara Alderman  

• Simon Primmer

• Sally Hasselby

National Association of Retired Police Officers (NARPO):

• Steve Wilcock

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

• Liam Kelly

Scottish Police Authority:

• Sharon Dalli

• Alasdair Corfield

Scottish Police Federation (SPF):

• David Kennedy

First Actuarial:

• Craig Moran

• James Allen

Government Actuary Department (GAD):

• Charlotte White

• Michael Scanlon

Scottish Public Pensions Agency (SPPA):

• Alan Wilkinson 

• Elle O’Kane

Welcome and apologies

1. The Chair welcomed everyone to the meeting. Apologies were received from Andy Tremayne (APCC).

Minutes of the meeting on the 4 July 2024

Action point 1: minutes were agreed. PABEW Secretariat to publish finalised minutes of 4 July 2024 on webpage.

Action log of 4 July 2024

The Chair went through the action log of 4 July 2024, which has been updated in the light of discussion. Key points of all the actions discussed were: 

2. Dan Murphy (PSA) asked for AP 5 from 28 March 2024 - to be reinstated.

28 March 2024 - Action point 5 : Clair Alcock (NPCC) to update SAB on the issue of early retirement factors for members retiring after age 55 as active members.

3. Outside of the AP2 from 28/03/2024 (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.) The Chair said all actions were to be marked as complete.

Home Office update and workplan

4. Simon Primmer (HO) explained that the HO policy team’s resources are limited, and the work plan extends beyond core policy tasks, covering a broad range of support functions. The work plan aims to clarify where the team is allocating efforts.

5. Simon Primmer (HO) explained the timeline for the contribution bands review implementation has shifted to October 2025, instead of April, based on discussions with the Treasury and recent developments, including the general election.

6. This timeline allows a 3-month public consultation, where stakeholders can provide feedback, recommendations, and input on achieving the target employee yield.

7. Administrators expressed the need for a transition period to integrate changes into their systems, and the plan now includes a 3-month buffer post-consultation to accommodate this.

8. Craig Moran (First Actuarial)  asked whether the October implementation aligns with other public service schemes.

9. Helen Fisher (HO) clarified that while some schemes will still implement changes in April, October was chosen to ensure thorough planning and sufficient engagement. Helen confirmed that the Home Office checked with the Treasury post-election to confirm if directives on meeting employee yield requirements remained unchanged, which they did. This solidifies the Home Office’s obligation to implement the changes.

10. The Chair questioned the feasibility of implementing the changes in October given the already high administrative load.

11. Clair Alcock (NPCC) explained that while the administrative burden would primarily fall on payroll systems, a 12-week preparation period (post-consultation) was deemed adequate by payroll providers, allowing for necessary payroll adjustments.

12. Helen Fisher (HO) that the timeline shift from April to October was partly to ensure payroll providers have enough lead time to integrate changes, preventing an unmanageable turnaround.

13. Gareth Wilson (CPOSA) asked whether there would be further meetings before the consultation document was finalised, as previous discussions had hinted at a consensus on proposed solutions.

14. Helen Fisher (HO) confirmed that the team would finalise the consultation document without further meetings, having integrated valuable input from past discussions.

15. However there were upcoming Engagement Sessions. Two sessions are scheduled while the consultation is active—one in mid-November (in-person) and one in mid-December (remote) with modelling tools to assist participants in exploring options. These sessions aim to give stakeholders opportunities for interactive input before the consultation closes in mid-January.

16. Clair Alcock (NPCC) suggested that the SAB may need extraordinary meetings to draft a response, given that no regular meetings are scheduled before the January deadline. Helen Fisher (HO) proposed confirming session dates by December so SAB could plan accordingly.

17. Simon Primmer (HO) explained Regulation 12 addresses compensation for police officers totally and permanently disabled within 12 months of a duty-related injury. It provides a lump sum to help officers adapt to lifestyle changes due to their disability.  Although affected by McCloud remedy timelines, the HO was finalising the consultation response from May-July 2021. This response is to be presented to the Minister soon, with publication and stakeholder engagement to follow if approved.

18. Once approved, the response and timeline for implementing Regulation 12 changes will be shared with the SAB and the wider sector.

19. Simon Primmer (HO) explained regulation 36 governs the criteria and process for awarding ill-health pensions, including eligibility, medical examinations, and appeals. In September, police forces were advised not to require medical examinations under this regulation, and any previous eligibility denials were to be reconsidered in favor of applicants.

20. Approximately 420 members have been impacted by Regulation 36, and updates will be provided to the SAB throughout the year as the department addresses current and future cases. The intention is to ensure a fair and transparent approach for both prospective and retrospective members affected by this regulation.

21. Simon Primmer (HO) focused on the broad scope of the policy team’s work, which includes managing police and fire pension-related correspondence from MPs and the public. The team also coordinates regularly with other government departments on issues impacting public sector schemes, specifically those for police and fire services.

22. He mentioned ongoing work related to ill-health cases and transitional protection but couldn’t disclose specifics due to confidentiality.

23. On guidance documentation he mentioned ongoing work to update and republish out-of-date guidance documents for police and fire pensions on gov.uk.

24. Helen Fisher (HO) noted that the team strives to balance consultation and policy workload while accounting for the seasonal spikes in routine tasks like finance and top-ups. She also noted the heavy volume of police correspondence the team manages, which exceeds that of fire.

25. Michael Scanlon (GAD) explained that the 2020 valuation, extended due to changes in the cost control mechanism and the McCloud judgment, was implemented in April 2024. Given the four-year cycle, the 2024 valuation is underway, targeting completion in three years to allow any employer contribution rate adjustments to be applied by April 2027.

26. Clair Alcock (NPCC) Raised the need to align SAB meetings with the PMAB guidance review timeline, suggesting SAB should engage at an optimal time to influence the review process effectively.

27. Helen Fisher (HO) noted potential delays due to budget outcomes, ongoing litigation, or other emerging priorities from central government. But stressed the importance of conducting a thorough review of the guidance documents, though acknowledging this work could be disrupted by higher-priority issues. She suggested an update on the review process at the January SAB meeting to provide a clearer picture of progress.

Action point 2: Helen Fisher (HO) committed to providing an update on the PMAB guidance document review at the January SAB meeting.

28. Simon Primmer (HO) discussed ongoing work on the McCloud remedy, particularly around managing compensation payments and updating guidance.

29. Dan Murphy (PSA) raised concerns about the opt-out issue, questioning why those who left due to pension reform can’t access legacy schemes under the remedy.

30. Helen Fisher (HO) clarified that the Act restricts the Scheme’s powers on contingent decisions and opt-outs, especially for members who fully left the service. She stressed that these constraints are set by legislation and Treasury guidelines.

CPI mismatch

31. Clair Alcock (NPCC) emphasised that the focus is to align on the next steps for addressing the CPI mismatch, including putting a proposal together for Treasury to adjust revaluation order dates. She highlighted the need to plan, with a potential 2026 target requiring significant lead-in time.

32. Helen Fisher (HO) stressed that any proposal to HMT needs strong justification, noting that past analyses didn’t factor in recent changes like the annual allowance increase. She suggested 2026 as a feasible timeline due to workload and administrative constraints.

33. Craig Moran (First Actuarial) pointed out that similar adjustments have been made in NHS and local government schemes, which could provide helpful precedent and guidance.

34. Gareth Wilson (CPOSA) expressed frustration about delays, urging prompt action to avoid future issues. Suggested using historical data and existing precedents to justify the need for change to Treasury.

35. The Chair summed up the consensus to commission updated analysis from First Actuarial, with timelines set for 2026 and agreement to gather more information on implementation challenges faced by NHS and other schemes.

36. Shabir Hussain (CPOSA) also stressed the urgency, recalling Treasury’s previous permission and recommending April 2026 for minimal volatility. He suggested enabling legislative change to implement adjustments promptly.

37. Michael Scanlon (GAD) Proposed consulting NHS and local government administrators to understand the real-world impact of similar changes.

Action point 3: SAB to address CPI mismatch by commissioning First Actuarial to update its analysis. A proposal to be prepared for the Home Office to present to the Treasury, justifying revaluation date alignment with CPI in the Police Pension Scheme with a target implementation date of April 2026.

Advice given to the scheme manager or local pension board [18(3)]

38. The Chair outlined potential roles of the Scheme Advisory Board, emphasising the need for the SAB to provide independent advice to ministers, support local pension boards and scheme managers, and address both policy and practical implementation issues.

39. The Chair proposed creating a focused SAB action plan based on prioritised areas where SAB can effectively intervene. She suggested SAB should  gather evidence, particularly data packs from local pension boards, to underpin an evidence-based approach.

40. Clair Alcock (NPCC) noted SAB’s limited power to enforce or drive significant outcomes, pointing out that guidance provided to scheme managers has not led to desired results.

41. Clair Alcock (NPCC) felt the SAB could formally write to scheme managers to gauge progress and add SAB’s voice in policy issues impacting members, especially issues like unauthorised payments where legislative support is lacking. The SAB’s involvement could strengthen NPCC’s ongoing appeals to HM Treasury (HMT) and HMRC.

42. Dan Murphy (PSA) highlighted the chaos in providing members with necessary documentation and responses, emphasising the lack of a centralised forum to address technical issues that directly affect members’ access to pensions and self-assessment requirements.

43. Shabir Hussain (CPOSA)  raised the need for immediate solutions to assist members with looming self-assessment deadlines when pension statements are delayed, suggesting HMRC accept provisional estimates.

44. The Chair concluded by reinforcing the need for the SAB to work on issues that align with its influence and mandate. She proposed a detailed follow-up meeting to develop a targeted action plan, leveraging evidence gathered from SAB’s interactions with local pension boards and scheme managers.

Action point 4: SAB to hold detailed follow-up meeting to develop a targeted action plan, leveraging evidence gathered from SAB’s interactions with local pension boards and scheme managers.

45. Gareth Wilson (CPOSA) and Dan Murphy (PSA) expressed frustration over limited representation and input on pensions, that staff associations feel they lack a unified voice.

46. The Chair stressed the importance of understanding SAB’s non-lobbying role and urged members to align their efforts when representing SAB. She suggested revisiting how SAB members communicate issues.

47. Shabir Hussain (CPOSA) reminded the meeting of SAB’s authority under Section 7 of the 2013 Act, advocating for a more proactive approach.

48. Clair Alcock (NPCC) noted a survey on data quality, highlighting discrepancies between reported and actual data, particularly around the concern around data for part time members and parental leave. She suggested that in future SAB could issue guidance on data scoring and quality.

49. The Chair flagged limited resources for SAB activities, encouraging members to contribute practically until additional resources are secured.

Pension dashboard staging

50. Clair Alcock (NPCC) raised concerns that the upcoming pension dashboards could lead to issues similar to the current remedy process, as they will require high-quality data and significantly increase member engagement across the entire pension scheme.

Governance - SAB chair engagement with local pension boards update

51. The Chair reported a positive meeting with chairs of local pension boards during Pension Awareness Week, where they discussed alignment between local boards’ priorities and SAB’s objectives. Local boards expressed support for greater SAB involvement and proactive support to aid their interactions with scheme managers.

52. Finding qualified staff was the top concern, as there is high competition for skilled workers across the sector. This shortage affects both scheme managers and administrators.

53. The Chair will attend upcoming local pension board meetings to understand their operations and identify opportunities for SAB support. A follow-up meeting with local pension boards is scheduled for early next year.

Reporting breaches to TPR

54. Clair Alcock (NPCC) highlighted that TPR now requires all breaches, not only those deemed “material,” to be reported. TPR aims to track compliance regarding annual benefit statements and other statutory deadlines.

55. NPCC have created a breach assessment form to help scheme managers document and assess breaches for potential reporting to TPR.

56. Dan Murphy (PSA) inquired if any actions follow once a breach is reported.

57. Clair Alcock (NPCC) explained that TPR has powers to enforce supervision or implement corrective measures, especially if breaches persist or are highly material. While TPR has traditionally focused on larger schemes, they are expanding oversight to include smaller schemes, with supervisory reviews possibly resulting from repeated breaches.

58. Clair Alcock (NPCC) proposed there was an action for SAB to ask schemes to inform SAB of any breaches reported to TPR, including the breach’s materiality, assessment, and mitigation measures. This transparency would enable SAB to understand common challenges and assess if breaches were anticipated and mitigated in advance.

Action point 5: SAB to ask schemes to inform the SAB of any breaches reported to TPR, providing details on the breach’s materiality, assessment, and any mitigation measures taken.

NI and Scotland update

59. Antonia Hoskins (DOJNI) Following discussions with the GAD and agreement from the Minister, a decision on addressing the pension shortfall has been reached, with consultations underway. Implementation is anticipated by the end of November or early December.

60. The Pensions Regulator spent a year with the scheme manager for observation. Issues arose when a new system failed to provide access to data, requiring immediate action and short-term solutions.

61. For future valuations, an agreement was made to review employee contribution rates to maintain alignment with scheme valuations. The Minister supports this, with no regulation changes required.

62. Due to legislative constraints, ill-health retirement eligibility now requires a two-year contribution period, effective from April 1, 2023. Legal counsel is being sought for retrospective considerations, with updates expected in November. Northern Ireland may implement changes ahead of England and Wales.

63. Elle O’Kane (SPPA) explained all retiring officers since October 2023 have received a Remedy Statement of Service (RSS) and made their choices. The Immediate Choice process was paused due to pension tax uncertainties, but with recent HMRC guidance on tax requirements and charges, it should resume shortly.

64. On Annual Benefit Statements out of the required statements, 91 have been issued, with remaining eligible officers expected to receive theirs soon. An upcoming meeting will finalise the timeline.

65. Contingent decisions are currently paused due to policy limitations. Officers can only buy back service under the 2006 scheme, not the 1987 scheme.

66. Minor corrections to remedy regulations are in progress, anticipated by the end of the year. Additionally, amendments to ill-health retirement regulations will begin consultation soon to address prospective access limitations. Only a few officers in Scotland are paying reduced contributions, with one actively in the ill-health retirement process.

67. Employer contributions will increase from 13.6% to 13.7%, with the Minister’s approval, and a consultation will start soon. Both this and other amendments are aimed for implementation by 2025-2026.

NPCC single shared services scheme manager

68. Clair Alcock (NPCC) said a paper was submitted by the NPCC regarding the need for a single shared services scheme manager. This was aimed at providing more consistent and coordinated responses across pension services.

69. NPCC seeks feedback from the Scheme Advisory Board (SAB) on the proposed single shared services scheme manager to assess if this would improve consistency and address existing challenges.

70. Gareth Wilson (CPOSA) said trying to get 43 chiefs along with PCC’s to agree to anything is difficult and in scheme management he could see the positive benefits of a single voice.

71. Shabir Hussain (CPOSA) posed the question, that had there been a single scheme manager since the beginning of the year would all of the negative issues raised at SAB not have occurred. Clair Alcock (NPCC) confirmed that the issues would have existed given multiple administrators. He also stated that there was no guarantee of any cash savings.

72. The Chair was interested in exploring PCC’s role as they do take an interest when Police officers report issues to them and said that could be put of the SAB action point.

73. Clair Alcock (NPCC) said NPCC was eager to draw out from members what could be achieved with consistency and why its good for policing. She pointed out as that is the cause of a lot of the current issues. Such as compensation schemes and evidence they need. She asked members to write in examples.

Action point 6: SAB to write to Clair Alcock (NPCC) with examples of where consistency could be beneficial to Policing regarding the NPCC single shared services scheme manager paper.

Letter to HMT and HMRC from Jeremy Vaughan

74. Clair Alcock (NPCC this was included on the agenda so that everyone had the opportunity to view the letters.

Letter from NPCC to staff associations / NPCC monthly bulletins

75. Clair Alcock (NPCC) said it was to note and to ensure it goes into the audit trail of paperwork.

Any other business 

76. The next meeting was scheduled for 14 January 2025.