Value for money digital service: technical overview

Practical information on the proposed digital solution for the value for money framework and how trustees and independent governance committees can start preparing for data submission.

Published: 11 August 2026

Why we have created this overview

We have produced this overview in response to industry feedback that early information on the value for money digital solution would be helpful before the joint Department for Work and Pensions (DWP) and Financial Conduct Authority (FCA) consultation on the value for money regulations and rules ends. It provides an overview of the proposed digital solution (also referred to as the ‘value for money database’) and how it will support trustees and independent governance committees (IGCs) to meet their obligations.

The value for money framework will require schemes to engage throughout the year, rather than through a single annual interaction. We recognise this will require both initial implementation activity and ongoing operational resource. By publishing this technical overview, we aim to help trustees and IGCs understand the proposed approach, identify areas requiring further consideration and begin planning for both short-term compliance and longer-term implementation across the value for money timeline.

This may include looking at:

how metric data will need to be collected and submitted through the service
the tasks, roles and governance needed to ensure the assessment can be completed

We will update this overview as the value for money framework progresses and regulations are finalised. We expect it to become a resource that trustees, IGCs and their advisers will come back to. We will update it to address feedback raised – whether from the consultation or later, as schemes progress preparing to meet the value for money requirements.

Background

The proposed value for money framework requires standardised metrics to be provided for all in scope arrangements. Trustees and IGCs will use these metrics to assess their arrangement’s value for money and provide a formal value for money rating and assessment report.

The initial proposal was for trustees and IGCs to provide this information using a flat file (CSV) template on their website and then compare themselves with the published data of three other arrangements. However, this was highlighted in the original consultation as:

additionally burdensome, in particular locating comparators
impeding a clear comparison to the wider market
presenting a risk to data quality due to data being sourced from self-publication and no validation available on the published data

The digital service solution has been designed to address these concerns by providing a central location for value for money responsibilities, reduce data errors, and support decision-making. It will be built to support the value for money policy intent, the Pension Schemes Act 2026, regulations, FCA rules and our codes of practice (when available).

Scope

The digital service will enable users (trustees and IGCs) to:

submit value for money metric data for initial assessment and then publication purposes, in line with the legislative requirements
access comparator data for assessments
submit value for money assessment outcomes for public disclosure

Data submitted via the digital service will be made available to The Pensions Regulator (TPR) and FCA to monitor, supervise and enforce the value for money legislative requirements in accordance with the value for money timeline (currently 2029 onward). More information on the first year (2028) adaptations can be found in the consultation overview.

Data submission

Trust and contract-based schemes will submit their arrangement’s value for money data via the TPR operated digital service. Both contract and trust-based schemes will access this using the TPR portal. This portal is currently used by trust-based schemes for existing regulatory reporting. Contract-based schemes will be required to sign in or register with the TPR portal if they haven’t previously done so.

During the annual submission window of January to March, firms and trustees can provide their value for money metrics by:

entering it directly in the web application
uploading a template (anticipated to be XSLX)
connecting via an application programming interface (API)

The service will apply automated checks at submission. These checks will not be able to verify the accuracy of the data submitted but will aim to reduce inputting errors by checking the format, completeness, range and consistency. Users will be informed of missing or incorrect data and can amend before their final submission. Responsibility to provide correct data is the responsibility of the trustees and IGCs.

Once they provide all the required data, a person responsible under the legislation will need to complete a declaration confirming the data is accurate to the best of their knowledge and belief, and that they have permission to sign this off. It remains the ultimate responsibility of trustees and IGCs that data submitted is complete and accurate.

This declaration can be withdrawn to allow edits to the data prior to 31 March annually, but each submission must be re-declared by the deadline. If value for money data is held by third parties, schemes should collate this prior to submission as the owners of this data.

Comparison against others

Following the data submission deadline, TPR will produce comparator group data. These groups are based on the draft policy criteria of arrangements open to new employers, and will include averages and ranges.

Trustees and IGCs will have access to this comparator data via the digital solution so they can conduct the value for money assessment for arrangements. This is expected to be available for export to allow a detailed assessment of performance to take place offline. This approach is based on consultation responses, interviews and user testing with schemes and other stakeholders.

The assessment is expected to have a main comparator group for stage 1 of the assessment (value delivered from investment performance), split by the arrangement’s decumulation aims for the at-retirement comparison data. All arrangement data is anticipated to be available to support rationalisation (stage 3). More information on the assessment stages can be found in the consultation, rules, and accompanying guidance.

Trustees or IGCs will produce value for money assessment conclusions using the approach provided by the regulations, TPR code and FCA rules to assess themselves. Their outcome will be informed by data and guidance, rather than automated determinations. The intent is that the solution supports (but does not replace) scheme governance and judgement. Trustees and IGCs remain accountable for value for money assessments.

Value for money assessment outcomes

Schemes or IGCs will submit a value for money rating for each in scope arrangement by the end of October annually. The outcome will be made publicly available alongside their metrics each November. Additional data may also be requested at this stage to provide context.

As part of the policy, schemes will also publish context on their value for money assessment themselves.

Any improvement or action plans triggered by amber or red assessment outcomes are expected to be handled outside of the digital solution. These will not be part of the data made publicly available.

Regulatory access and oversight

TPR and FCA will be able to access value for money data and outcomes at aggregate and arrangement level for use in connection with their respective regulatory functions including monitoring, supervisory activity and market insights.

The solution will be auditable and traceable by regulators, for example which users provided data or completed the declarations.

Data may also be disclosed to other regulators and government bodies, to the extent appropriate and permitted by law.

Publication of data

In accordance with the value for money legislation, metric data, assessment reports and ratings will be made publicly available. The date of this is dependent on final regulations and rules.

Further engagement with industry will be undertaken where appropriate to assist with the practical implementation of the legislation.

High level architecture

The solution consists of:

secure data ingestion
automated validation checks on data provided and user prompts
a central value for money data repository
access controls – only authorised users for the scheme can provide and access data
reporting and disclosure interfaces

The digital service will comply with Government Digital Service standards for accessibility and design, public sector security, data protection and resilience standards.

Providers wishing to use our APIs to provide or access data will be required to authenticate themselves with us in advance, ensuring they are allowed to provide data on behalf of the arrangement and meet required security standards.

The solution anticipates a one-to-many relationship between schemes and default arrangements. Each arrangement will be given a unique identifier to support consistency and future integration.

TPR will continue to research and test the value for money digital service throughout 2026 and 2027 as it is developed. This testing will cover core functionality, including data transfer and submission, and completing the assessment process online. The focus will be on usability and data management to ensure the service is robust and effective ahead of its planned launch in 2028. This activity will run alongside separate work to consult on policy and data definitions.