Jurisdiction(s):
United Kingdom

CDC Phase 2: extending to unconnected multi-employer schemes; draft 2025 regulations on authorisation, proprietor governance and actuarial equivalence, plus forthcoming TPR/FRC guidance and DC transfers without consent

Published on: 03 December 2025

Published by a LexisNexis Pensions expert

Legal News

Article summary

What was the background to the consultation?

Work on the CDC legislative framework began with a consultation in 2018; over time this process ultimately resulted in the measures set out within the Pension Schemes Act 2021. During 2022, secondary legislation, alongside the Pensions Regulator’s CDC Code of Practice, followed and thereby completed Phase 1 of CDC development in the UK. The first operational CDC arrangement—the Royal Mail Collective Pension Plan—then received authorisation in 2023 and subsequently launched in October 2024. The 2021 Act, together with the 2022 regulations (SI 2022/255), had been drafted specifically with the Royal Mail’s particular scheme design in mind. Hence, only single- or connected-employer arrangements, offering a very defined package of scheme benefits, could legally be created and, to date, the Royal Mail scheme alone has obtained authorisation. From the very outset, however, the pensions industry and large schemes have consistently called for regulations to enable additional CDC structures and designs to be brought forward. In 2023, once the initial regulations were settled, the DWP commenced Phase 2 of CDC development and consulted on broadening the provisions beyond single or connected employers so as to accommodate unconnected multi-employer schemes (UMES) as well...

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