Pensions - Articles - Comments on deadline for 2nd Pensions Commission report


Catherine Foot, Director of the Standard Life Centre for the Future of Retirement, comments on the consultation deadline for the interim report of the Second Pensions Commission.

"The Pensions Commission has a once-in-a-generation opportunity to build consensus around the reforms needed to deliver better retirements for millions of people. If it does only one thing, it should recommend increasing minimum auto-enrolment contributions from 8% to 12%.
 
"Auto-enrolment has been one of the UK's biggest public policy successes, but millions of people are still not saving enough and risk reaching retirement with far less income than they expect or need. The Commission provides an opportunity to put this right. We welcome the Commission's focus on helping people turn their pension savings into retirement income. The initial report was relatively negative on the Pension Freedoms, but they should be seen as part of the solution, not the problem.
 
"Retirement is no longer a single cliff-edge moment. More people are working later, phasing their retirement, or moving in and out of work. Pension Freedoms give people the flexibility and control to manage that transition. The priority now should be better support and guidance, with defaults acting as a safety net rather than the first choice for most savers.
 
"The reality, though, is that reforms alone won't move fast enough for everyone. For many people in Generation X, time is running short. More than half are at risk of inadequate retirement incomes, and many could face a serious pension shock unless action is taken. Supporting longer working lives through flexible working, age-inclusive recruitment, better careers support and help for people with health conditions and caring responsibilities must be part of the answer."
 
Specific recommendations
 
1. Increasing contribution levels
We recommend that minimum automatic enrolment contributions are increased from 8% to at least 12%, bringing the UK closer to levels associated with achieving a ‘Living Pension’ and more in line with international comparators. Over time, there should be a move towards a more balanced contribution structure between employers and employees (for example, a 6/6 split), reflecting a shared responsibility for retirement outcomes.
 
To deliver this sustainably, increases should be:
Implemented through a clear, pre-announced pathway, with incremental increases (e.g. 0.5% per year)
Phased and predictable, supporting planning and minimising disruption
Supported by targeted mitigation for lower earners
 
2. A framework for increasing contributions
We propose a structured framework to guide decisions on contribution increases, based on a small number of objective economic and labour market indicators. This framework:
Ensures increases are delivered at the right time and pace
Balances adequacy with affordability
Provides clarity and certainty for employersIs underpinned by a statutory requirement for a review every five years
 
This approach would ensure progress towards higher contributions while maintaining resilience during periods of economic stress.
 
3. Supporting participation through flexibility
Maintaining participation will be critical as contribution rates increase. We recommend introducing targeted flexibility within the automatic enrolment system, including:
Temporary opt-down or pause mechanisms, allowing individuals to respond to short-term financial pressures without leaving the system
Protections for employer contributions, ensuring individuals are not disproportionately penalised for temporary income shocks
 
These measures would reduce opt-outs, improve persistency, and support better long-term outcomes, particularly for lower and moderate earners.
 
4. Extending coverage
We support the full implementation of the 2017 Automatic Enrolment Review, including:
Lowering the minimum age to 18
Removing the Lower Earnings Limit
Calculating contributions from the first pound of earnings
 
These reforms would improve fairness, increase participation, and boost overall contribution levels, particularly for younger and lower-paid workers. At the same time, flexibility must be retained to reflect varying saving capacity across the income distribution.
 
5. The cost of delaying reform
Delaying increases in contribution rates would significantly reduce their effectiveness, particularly for those closer to retirement. While younger savers benefit most from early action, older cohorts (especially Generation X) face the greatest losses from delay, with a rapidly narrowing window to improve adequacy. Without clearer support and earlier warning, many in this cohort risk experiencing a “pension shock” as they approach retirement decision-making and discover that their expected retirement income is materially lower than anticipated. Early and decisive action is therefore essential.
 
6. Investment, value for money and economic growth
Investment returns are a critical determinant of retirement outcomes. The Commission is right to emphasise the importance of net returns and long-term value. We support the implementation of a robust Value for Money framework that:
Moves beyond a narrow focus on cost
Prioritises net returns and member outcomes
Supports investment in a broader range of assets
 
Greater scale and more diversified investment strategies can significantly improve saver outcomes, while also unlocking substantial investment in UK productive assets, supporting economic growth, productivity, and innovation.
 
7. The role of employers
Employers play a critical role in supporting pension saving. While there is broad support for higher contributions, this must be balanced with affordability and implemented through a clear, phased, and well-signalled roadmap. Contributions should be considered as part of total remuneration, ensuring alignment with wages, labour market conditions, and business sustainability.
 
8. Supporting incentives and system efficiency
Stable and effective incentives, particularly tax relief, are essential to maintaining engagement with pension saving. Policy certainty is critical, and frequent changes risk undermining confidence and distorting behaviour. We also support greater alignment between regulatory regimes to reduce inefficiencies and ensure that the system consistently promotes long-term outcomes for savers.

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