The ECPA welcomes the opportunity to respond to the Consultation. As an organisation representing the employer covenant industry, we have chosen not to respond to the individual Consultation questions but wish to draw attention to the importance of the role of employer covenant when trustees and sponsors make decisions on surplus release, and recommend it is explicitly reflected in the final Regulations.
Our key recommendation is that the final Regulations should expressly require trustees to consider the employer covenant before agreeing to any surplus release, with confirmation of that consideration reflected in the subsequent notification requirements to the relevant regulatory body / bodies. More …
2 September 2026 - ECPA response to DB Surplus Flexibilities consultation