Size and scale of total employer late payments to employee pension schemes from 2022 to 2024
FOI reference - FOI-420
Date - 22 October 2025
Request
I would like to understand the size and scale of total employer late payments to employee pension schemes for each calendar year in 2022, 2023 and 2024 in the UK under the TPR jurisdiction I would like to understand:
- the annual value of late payments (e.g. 22nd month following) by all UK employers
- the % of this versus total pension payments made by all UK employers
- the annual value of "material payment failures (e.g. more than 90 days late) by all UK employers
- the % of this versus total pension payments made by all UK employers
- the total value of all employer pension payments to employee schemes under TPR jurisdiction for each of the 3 years
Response
Under section 12 of the FoIA public authorities are not obliged to comply with a request for information where the cost of complying would exceed the appropriate limit in the fees regulations: The Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004 (SI 2004/3244), which, for us, is set at £450. Staff costs are fixed at £25 per person per hour. This represents the estimated cost of one person spending 18 hours in determining whether we hold the information, locating, retrieving, and extracting it.
I can confirm that the information you have requested is held, but in line with section 12 of the FoIA we are not able to provide the information to you because this would take us 32 hours in excess of the applicable time limit to determine whether the appropriate material is held and to locate, retrieve and extract that information. Below is a breakdown of the estimated time required.
- Determining whether the information is held – Approximately 30 minutes to review the request in detail and confirm whether the data is held.
- Locating the information or relevant documents – Around 15 minutes to check if any archived data exists for the three years specified that could be used for the analysis.
- Retrieving the information – It is unlikely that archived data is available, so we would need to write SQL code to extract the information from our databases. While some existing code could be adapted, it would require amendments to obtain the precise details requested in part (c) of the original request. The estimated time for coding, testing, and quality assurance is approximately 3 hours.
- Extracting the information – After compiling the data into an Excel workbook, manual checks would be required to identify which late payment reports meet the threshold for a ‘Material payment failure,’ as explained in our previous response. Given that there are over 2 million reports, this process could take two staff members two days each, equating to around 28 hours.
Total estimated time: Approximately 31.75 hours.
Having carefully considered your request, we are not able to provide any of the requested information within the appropriate cost limit and do not consider that the request can be refined to bring it within the cost limit. This is because the majority of the work required relates to extracting and manually reviewing a very large volume of data, over two million individual reports, to determine which meet the threshold for a ‘Material payment failure.’ Even if the scope were narrowed to a smaller time period or subset of data, the process would still involve significant coding, testing, and quality assurance, followed by extensive manual checks. These steps alone would exceed the statutory limit, meaning that refinement would not reduce the cost to an acceptable level.