LawDeb responds to the FCA's latest consultation on the Value for Money Framework

On 13 July 2026, the FCA, DWP and TPR published CP26/25, the latest stage in the joint consultation on the Value for Money (VfM) Framework, building on the original 2024 consultation (CP24/16) and last winter's further consultation (CP26/1).

Elizabeth Hartree, Director and Head of DC at LawDeb, summarises LawDeb's response.

"This is our third response on the VfM Framework, and it's clear the FCA has listened carefully to industry feedback along the way. We're supportive of the direction of travel, the simplification of backward-looking metrics, the removal of the external advice requirement for forward-looking metrics, and the bedding-in period with no automatic consequences for ratings are all sensible, proportionate changes.

Our main concern now is what happens when an arrangement is rated amber. As things stand, closure to new business could become a self-fulfilling outcome, employers move away, advisers can't recommend the scheme, and funds dry up, regardless of whether the underlying issue is genuinely addressable. We've recommended a defined cure period, so trustees have a fair opportunity to demonstrate a path back to green before the market makes the decision for them.

We're also mindful that uniform risk metrics and granular disclosure of asset allocation can push providers toward the same safe, comparable positioning, at a time when the wider policy agenda is actively encouraging bolder allocation to private markets. And where employers go further for their members, bearing costs directly or offering benefits beyond what's available in the open market, we think trustees should be able to recognise that value, rather than the Framework's metrics quietly pointing toward consolidation instead."

View our response summary here and do reach out to Elizabeth or to Chris Hay to discuss LawDeb's full response.