Value for Money
Member outcomes are the ultimate test of trustee governance. A scheme with strong policies, a well-completed ORA, and regular board meetings is not fulfilling its fiduciary duty if its members are paying more than necessary for their retirement savings. The Pensions Authority expects trustees to actively assess whether their scheme delivers value for money (VFM) for members — and to document that assessment as part of their governance record.The PA’s Supervision 2025–2029 strategy identifies fees and charges as a standalone SRP pillar. Trustees who cannot demonstrate that they have actively considered VFM — not just assumed it — will face follow-up questions in any supervisory engagement.
The Trustee’s VFM Obligation
Under IORP II, trustees have a statutory duty to act in members’ best financial interests. This duty includes:- Understanding what the scheme costs in total — not just the trustee’s own fees, but all layers of cost including investment management, administration, custody, and platform fees
- Assessing whether those costs are reasonable in the context of the services and outcomes delivered
- Considering whether alternative arrangements (such as migration to a master trust or DC consolidation vehicle) would deliver better outcomes for members
- Documenting the VFM assessment and making it available on request
Cost Transparency Standard (CTS)
The Cost Transparency Standard, developed by the PLSA and adopted in Ireland with PA guidance, provides a framework for investment managers and administrators to disclose costs to trustees in a consistent format. What the CTS covers:- Investment management charges (AMC, ongoing charges, transaction costs)
- Scheme administration fees
- Custody costs
- Advisory and governance costs
- The reasonableness of those costs relative to the outcomes delivered
- Comparison to alternative providers or structures
- Member-level impact of costs over time
VFM Dashboard
PensionPortal.ai’s VFM Dashboard provides a structured environment for conducting and documenting your scheme’s VFM assessment. Navigate to Schemes → [Your Scheme] → Value for Money.Review your provider contracts
The Provider Contracts table lists all scheme service providers with their annual cost, contract type, renewal date, and cost category. Sort by any column to identify your highest-cost providers or those approaching renewal.
Run the benchmarking comparison
The Benchmarking panel compares your scheme’s total cost structure against a master trust comparator. The comparison shows:
- Total annual cost for your scheme
- Equivalent cost in a master trust structure
- Estimated annual saving if the scheme migrated The savings banner updates automatically as you add or edit provider costs.
Review the member impact
The Member Impact section translates scheme costs into member-facing metrics:
- Cost per member — total annual scheme cost divided by active membership
- Scheme cost ratio — total costs as a percentage of assets under management
- 10-year fee drag — projected impact of current costs on a typical member’s retirement pot over 10 years These metrics allow trustees to understand the real-world impact of governance decisions on member outcomes.
Review the VFM Summary Card
The VFM Summary Card provides an overall RAG (Red / Amber / Green) status based on benchmarking and member impact metrics:
- Green — scheme costs are competitive; document the assessment and review in 12 months
- Amber — costs are above benchmark; trustees should seek competitive quotes at next renewal
- Red — costs are materially above benchmark; trustees should actively consider alternatives and document their rationale for maintaining current arrangements
Linking VFM to Other Governance Areas
VFM does not sit in isolation. It connects to several other governance obligations:| Governance area | VFM connection |
|---|---|
| Own Risk Assessment | Cost and value risk should appear in the ORA — especially where costs are above benchmark or a material provider is approaching renewal |
| Investment Policy Statement | The IPS must reflect the trustee board’s investment cost objectives; a high-cost investment structure requires justification in the IPS |
| Outsourcing Register | Provider cost data should be held alongside contract terms in the outsourcing register; renewal dates should trigger VFM reviews |
| Board Minutes | The VFM assessment should be a standing annual board agenda item; the conclusion must be recorded |
| OMA Triage | For OMA schemes considering transition, the VFM comparison of current scheme vs. master trust is a key input to the consolidation decision |
What Good VFM Governance Looks Like
The Pensions Authority expects to see evidence that trustees have:- Identified all costs — using CTS-compliant disclosure from all service providers
- Benchmarked those costs — against at least one meaningful comparator (master trust, market data)
- Assessed the member impact — understanding how costs affect member retirement outcomes
- Made a documented decision — either confirming current arrangements represent VFM, or implementing actions to address identified gaps
- Reviewed regularly — VFM assessment should be annual, or at provider renewal
The previous Cost Comparison page at
/schemes/[id]/cost-comparison/ has been replaced by the VFM Dashboard. If you have bookmarked the old URL, it will redirect automatically to the new VFM Dashboard.