The Department for Work and Pensions (DWP) has launched its consultation on “Surplus Flexibilities for Defined Benefit Pension Schemes: Unlocking Value for Employers and Scheme Members.” The consultation proposes new regulations that would make it easier for well-funded defined benefit pension schemes to release surplus funds to sponsoring employers under certain conditions.

On the surface, the consultation talks about creating benefits for employers, pension schemes and members. However, one significant omission stands out.

There is no proposal requiring pension scheme members themselves to be consulted before decisions are made about the use of surplus funds.

This is deeply disappointing.

For many people, a defined benefit pension represents decades of work and careful saving. Although employers have contributed significantly to these schemes, so too have employees, often making contributions throughout their working lives. Pension scheme members are not bystanders – they are the very people whose retirement security depends on these funds.

If governments believe that good governance is built on transparency, accountability and participation, it is difficult to understand why the voices of millions of pension scheme members are absent from these proposals.

At OPAAL, we believe that people should have a meaningful say in decisions that affect their financial future. Before surplus funds can be released or used in new ways, there should be a clear expectation that scheme members are consulted and their views properly considered.

The consultation remains open until 2 September 2026, providing an opportunity for individuals, trustees, employers, representative organisations and pension scheme members to make their views known.

We encourage anyone with a defined benefit pension—or anyone concerned about the principles of fairness and member engagement—to respond to the consultation and ask the Government to strengthen these proposals by introducing a requirement to consult pension scheme members before surplus funds are distributed.

You can read the consultation and submit your response here:

DWP Consultation: Surplus Flexibilities for Defined Benefit Pension Schemes

Meaningful consultation is not an obstacle to good decision-making—it is an essential part of it. If pension scheme members are expected to trust the system that safeguards their retirement income, they should also have a voice when fundamental decisions are being made about the assets they helped to build.

OPAAL will continue to press for pension policies that place the interests and voices of older people and pension scheme members at the heart of Government decision-making.