Hammersmith and Fulham Pension Fund Tightens Penalties for Late Employer Contributions
Hammersmith and Fulham Pension Fund has introduced a revised administration strategy, implementing stricter financial penalties for employers who fail to submit contributions and schedules on time. The Pension Fund Committee approved the updated strategy, which is mandatory for all Local Government Pension Scheme (LGPS) pension schemes, aiming to ensure consistent and resilient pension administration.
The updated strategy places a strong emphasis on timely and accurate record-keeping and contributions. To deter persistent poor performance by scheme employers, the financial penalties have been increased.
Specific Penalties and Deadlines
Under the revised strategy, employers face specific charges for late submissions. For late payment of monthly contributions or deficit payments, the charge is £250 per incident after two warnings within a scheme year. Similarly, late monthly data submission to LPPA and schedule/remittance submission to the LBHF Pensions Team will incur a £250 charge per incident.
Penalties are also in place for other administrative lapses: £125 per case for late notification of new joiners, £125 per case for leavers under 55 or opt-outs, and £250 per case for any type of retirement.
Contributions and deficit payments are considered on time if they are cleared by the 19th of the month following the one in which the contributions were deducted. For example, contributions deducted in January must be paid by February 19th. Monthly data and schedule/remittance submissions to LPPA and the LBHF Pensions Team must also adhere to this 19th of the following month deadline.
Enforcement and Consequences
The Pension Fund will actively monitor employer performance regarding the timeliness and accuracy of data submissions and contribution payments. Employers will be notified of missed deadlines, and steps will be taken to ensure appropriate performance levels are maintained. The Fund reserves the right to implement the charging policies and report non-compliant employers to The Pensions Regulator in cases of persistent late or incorrect contributions or data submissions.
Beyond financial penalties, repeated failures to meet contribution deadlines or submit accurate data on time can lead to more severe consequences. Employers may be reported to The Pensions Regulator, which has the authority to take legal action and impose fines. For admitted body employers, their admission agreement could be terminated, meaning their LGPS employees would lose eligibility for scheme membership, necessitating a cessation calculation.
Support and Appeals
The Fund acknowledges that unforeseen circumstances can arise and will work closely with scheme employers experiencing difficulties. Assistance may be provided through case-specific support or general training, with an agreed action plan. However, if improvements are not made following a warning, charges may be issued. Employers reaching three charges in a scheme year, or where the Fund deems an action to be of significant material interest, will be reported to The Pensions Regulator. The policy underscores that financial penalties are intended as a last resort to deter persistent poor performance.
Expected Impact
These stricter penalties are expected to significantly improve the quality of data submitted by employers, facilitate reconciliation processes, and ultimately contribute to the accurate and timely administration of pension benefits. By ensuring timely contributions, the financial health of the fund is supported, and administrative efficiency is enhanced through better data quality and a reduced need for corrective actions.
The revised strategy is detailed in the Pension Administration Strategy document, which can be found as part of the Public reports pack for the Pension Fund Committee meeting on 12th October 2026.
Public reports pack 12th Oct 2026 19.00 Pension Fund Committee
Agenda frontsheet 12th Oct 2026 19.00 Pension Fund Committee