Enfield Pension Fund Responds to LGPS 'Access and Fairness' Consult

The Enfield Pension Fund is preparing to respond to the Ministry of Housing, Communities and Local Government (MHCLG) consultation on proposed changes to the Local Government Pension Scheme (LGPS), aimed at improving fairness and access. The announcement was made at the Local Pension Board meeting on 3 July 2025.

The MHCLG launched the consultation on 15 May 2025, with a closing date of 7 August 2025. The Enfield Pension Fund will be responding in full to the MHCLG consultation and plans to share its response with the Pensions Board at the next meeting.

The proposals under consideration cover a wide range of issues, including:

• Survivor benefits and death grants: Equalising survivor benefits and removing age limits for death grant eligibility.
• Gender pension gap benefits: Addressing disparities through changes to unpaid leave policies and cost alignment for buying back lost pension. The proposed changes to unpaid leave policies include:
  • Making authorised absences of less than 31 days automatically pensionable.
  • Aligning the cost of buying back lost pension for authorised absences of over 30 days with the standard member contribution rates.
  • Extending the time limit for electing to buy back lost pension from 30 days to 12 months.
  • Removing the limit that provides employers must only share the cost of buying back lost pension for a maximum period of three years.
  • Updating the definition of child-related leave to include all periods of additional maternity, adoption and shared parental leave without pay.
• Gender pensions gap reporting: Making gender pension gap reporting mandatory for administering authorities and employers with over 100 employees.
• Opt-outs: Mandating the collection and reporting of opt-out data to understand who is opting out and why. The consultation includes a proposal to make the collecting and reporting of opt out data mandatory, including use of a standard form to be used by all administering authorities. Specific data to be collected includes:
  • Rate of opt-outs (mandatory reporting for administering authorities in the annual report).
  • Additional opt-out data collected by MHCLG, e.g., ethnicity, religion, marital status, hours, salary etc.
  • Use of a mandated opt-out form.
• Forfeiture: Removing restrictions on forfeiture provisions to reclaim financial losses from members' benefits. The consultation aims to remove the following restrictions on forfeiture provisions:
  • The requirement that a member must have left employment because of the offence for forfeiture to be possible.
  • Abolishing the three-month time limit for an application to be made.
  • Removing regulation 92 (interim payments directions).

The forfeiture provisions are intended to reclaim financial losses from members' benefits.

• McCloud remedy: Correcting issues with existing remedy regulations related to divorce, death grants, interest, and transfers.
• Abolition of LTA changes: Revoking regulations related to the lifetime allowance (LTA) and updating actuarial guidance. The expected impacts of revoking regulations related to the lifetime allowance (LTA) include:
  • Revoking regulation 50 (limit on total amount of benefits) and withdrawing LTA actuarial guidance.
  • Amending the definition of a BCE.
  • Updating actuarial guidance on cash commutation to include the payment of the Pension Commencement Excess Lump Sum (PCELS).
  • Legislating for the maximum PCELS to be 25% of the capital value of the benefits being crystallised (subject to contracting out limits).
• Other changes: Allowing small pot payments to members who left the LGPS before 1 April 2008, and allowing deferred members to buy additional pension with in-house AVC pots.

The consultation also seeks input on the potential administrative burden and the government's duty under the Public Sector Equality Duty, given that some amendments are backdated. The consultation includes questions on the potential administrator burden as some of the suggested amendments are backdated meaning administering authorities will need to revisit affected cases. The document does not specify how these burdens might affect smaller administering authorities.

Tim O'Connor, Exchequer Manager - Pensions, presented the quarterly monitoring report, which included the LGPS consultation, to the Local Pension Board. The report was noted by the board.