We welcome several aspects of the proposals, including the encouragement of innovation via new entrant pathways for DC schemes, flexibility for values-based defaults and the ambition to enhance local investment and pooling structures.

However, challenges remain. Most notably:

• The absence of a robust framework for assessing sustainability within default arrangements.
• The lack of action to regulate investment consultants, despite their systemic influence on outcomes.
• A rushed timetable for LGPS pooling, which risks undermining the quality and effectiveness of implementation.

We also believe the most urgent issue facing UK pensions – adequacy – has been deferred, when it should have framed the investment reforms from the outset. We look forward to engaging with the upcoming phase of the Pensions Review on this critical issue.