The NAPF has responded to the DWP’s consultation on the Transfer of Employment Regulations. While we agree that the current Transfer of Employment (Pension Protection) Regulations 2005 are inadequate because they can require employers who are taking on employees from an occupational scheme to pay more than the transferring employer paid into a money purchase scheme, the proposed regulations will allow many employers to pay less than the transferring employer paid. 

Employees transferring from one employer who provides a money purchase scheme to another employer who provides a money purchase scheme should receive the same contributions from the transferee employer as the transferor employer paid.  This is the situation that applies where the employers provide contract-based provision, and it should apply to occupational pension provision as well. 

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