The NAPF feels that charges should be considered as part of a wider examination of the value for money provided to scheme members, and not separately from it. The NAPF, in its response, emphasises the significant role of governance and scale in ensuring good outcomes for members.

The NAPF has said that if the Government does bring in a cap, the comply and explain option would work best for our members. The NAPF has outlined a number of concerns with a cap on charges, including the constraints it may put on innovation in investment products and the potential reluctance of schemes to appoint at-retirement advisers if this increases the charge to a level above the cap.

The NAPF has also encouraged the Government to pursue increased transparency and disclosure of costs and charges using the NAPF-led Pension Charges Made Clear: Joint Industry Code of Conduct.

The NAPF is extremely concerned about the short timescales and the minimal consideration by the Government of transitional arrangements for employers that are about to go through, or have already gone through, automatic enrolment.

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