Streamlined scheme valuations under the new funding code
10 December 2025
The Pensions Regulator’s new funding code has been in place for over a year, and the first wave of schemes will shortly reach their statutory valuation deadline. Associate Partner Scott Harrison argues that the predicted complications, delays and spiralling costs are far from inevitable.
At First Actuarial, we’ve taken our own path to scheme valuations under the new funding code, and it’s paying off. We’re submitting valuations for our clients well before their deadline – on average five months ahead. And importantly, we’re making the process as painless as possible for scheme trustees.
How are we achieving this?
The answer is to keep everything simple and focus on what matters.
A pragmatic, proportionate approach
The new code was designed to codify good practice, not reinvent the wheel. For schemes with sensible, well-thought-out strategies, compliance shouldn’t mean tearing up plans or incurring unnecessary costs. Our approach reflects that.
Rather than overengineering the process, we concentrate on delivering key figures soon after the valuation date. This means trustees get the information they need to seek investment and covenant advice without delay.
This approach quickly determines whether a streamlined approach can be taken – with many trustees of well-funded schemes opting to align their low-dependency funding basis and technical provisions.
For schemes that need it, we offer an interactive tool to design a journey plan to low dependency during an initial meeting. In most cases, this identifies a sensible strategy right away.
This streamlined approach avoids the bottlenecks and inflated fees we’re seeing elsewhere. For our clients, the valuation process has been smooth, efficient and cost-effective.
The statement of strategy – easier than you think
There’s a common misconception that preparing the statement of strategy is a daunting and costly task. In our experience, that impression is wrong, particularly for Fast-Track valuations.
When advisers have done their job properly throughout the valuation, the statement of strategy can simply capture existing advice and decisions already made. There’s no need for fresh consultancy or extra rounds of recommendations – completing the statement is a straightforward matter of recording what’s been agreed.
Far from being a complex obstacle, it’s simply about entering data that’s already available, not starting from scratch or paying for unnecessary advice.
Avoiding the fear factor
We know that some advisers are fearful of breaching The Pensions Regulator’s (TPR) guardrails and triggering regulatory intervention. Our message is simple – if your strategy is justifiable and proportionate, press ahead. Don’t let fear drive inefficiency.
TPR isn’t expected to report on its regulatory approach until well into 2026. In the meantime, trustees should focus on putting in place a strategy that works for their scheme – not on second-guessing intervention that may never happen.
Real results, happy clients
Scheme trustees who have completed their valuation have appreciated our pragmatic advice, our ability to keep costs proportionate, and our commitment to making the process as painless as possible.
As David Archer, Trustee Director at Zedra Governance Limited, said:
“The advice from First Actuarial in support of our recent valuation under the new funding code has been clear, practical, and focused on what matters most. All their recommendations were sensible and proportionate. They have been excellent at providing advice that is adept and technically accurate, and at the same time pragmatic and sensible. They’re great at explaining actuarial and regulatory requirements in plain and straightforward language – and doing so cost-effectively.”
Looking ahead
As we submit more valuations in the coming weeks and months, we plan to share insights and lessons learned. But one thing is clear: early engagement and a proportionate approach work. It’s a simple process that delivers compliance without complexity – and keeps costs under control.
If you want an adviser who can deliver a valuation process that’s efficient, pragmatic and focused on your needs, talk to us today. We’re ready to help you navigate the new funding code with confidence.