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Hamilton Academical Football Club Limited

FOI reference - FOI-480
Date - 6 July 2026

Request

I seek any information that can properly be disclosed regarding:

  1. Whether Hamilton Academical Football Club Limited has complied with its automatic enrolment and workplace pension obligations since 19 December 2025.
  2. Whether any pension contributions remain outstanding.
  3. Whether the Club has been subject to any compliance or enforcement action.
  4. Whether any financial penalties have been imposed.
  5. Whether any notifications or referrals have been made to other regulatory bodies, including the Scottish Professional Football League or the Scottish Football Association.

If any part of the request falls outside the scope of the Freedom of Information Act, I would be grateful if you would treat this correspondence as a request for any information that may otherwise be disclosed or explain the appropriate statutory route by which such information may be sought.

Response

I confirm that we hold the information you have requested. However, the information you have requested is exempt from disclosure.

Section 44(1)(a) – restricted information under s82 PA04

As we have been given strong powers to demand documents and other information from trustees, employers and others, those powers are also balanced by restrictions on how we disclose the information provided to us. The type of information you have requested would be ‘restricted information’. Restricted information is defined at section 82(4) of the Pensions Act 2004 (PA04)1 as:

‘…information obtained by the Regulator in the exercise of its functions which relates to the business or other affairs of any person’.

Under section 82(5) of the PA04 it is a criminal offence to disclose such information except as permitted under that Act.

Whilst the FoIA is based on the presumption of releasing information, section 44(1)(a)2 of the FoIA provides an absolute exemption to the requirement to disclose any information if its disclosure is prohibited by or under any enactment. In this case, section 82 of the PA04 prohibits disclosure and we are unable to disclose this sort of information. This exemption is absolute and does not require a public interest assessment be undertaken.

Duty to provide advice and assistance

As the statutory prohibition on disclosure applies to the information in its entirety, there is no alternative statutory route by which this information may be disclosed in response to your request. Accordingly, we are unable to provide the information under the FoIA or through any other disclosure mechanism available to you.

If you have any general requests for information or guidance concerning your pension, we recommend contacting MoneyHelper. They provide free, impartial guidance and can recommend further, trusted support if you need it. Their contact details are:

Telephone: 0800 011 3797
www.moneyhelper.org.uk/contact-us 

MoneyHelper also has a specific page of guidance on their website for concerns about late payments 

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