RSM UK Warns Strong Guardrails Essential for New DB Pension Surplus Flexibilities
By Ali Paterson · 12 June 2026

Quick Summary
The UK government has launched a consultation on DB pension surplus flexibilities, allowing schemes to distribute excess funds. While RSM UK welcomes the move, they emphasize that strong guardrails and low-dependency thresholds are essential to protect members and ensure trustees manage the shift from maximum security to managed risk.
How Will DB Pension Surplus Flexibilities Impact Scheme Members?
The introduction of DB pension surplus flexibilities represents a fundamental shift in how defined benefit schemes operate. By moving from a "buy-out" focus to a managed risk strategy, the government aims to unlock capital for economic growth. However, RSM UK notes that this transition inevitably transfers some risk back onto the system. To mitigate this, low-dependency thresholds act as a pragmatic compromise, ensuring a minimum prudence standard is maintained before any funds are distributed.
- Managed risk approach replaces the traditional maximum security buy-out model.
- Low-dependency thresholds serve as the primary safety mechanism for members.
- Employer covenant strength becomes the critical factor in managing potential risks.
What Challenges Do Trustees Face with Surplus Distribution?
Trustees must navigate increased administrative burdens and higher operational costs when pursuing a DB pension surplus distribution strategy. RSM UK highlights that professional fees for actuarial, legal, and investment consultants will likely rise as schemes work to meet strict criteria. Furthermore, in unionised industries, the process of sharing surpluses between employers and members may lead to complex negotiations that require expert governance to resolve effectively.
- Higher running costs due to increased reliance on professional consultants.
- Regulatory oversight pressure on The Pensions Regulator (TPR) will intensify.
- Complex member consultations are expected, particularly in large, unionised sectors.
Which Schemes Are Most Likely to Benefit from These Changes?
The new DB pension surplus rules are primarily relevant to large-scale schemes where investment outperformance can consistently exceed annual running costs. RSM UK suggests that only schemes of a certain size will generate a worthwhile surplus increase available for distribution. For smaller schemes, the cost of meeting regulatory requirements and the difficulty of achieving net surplus on a low-dependency basis may make these flexibilities less attractive or practically unviable.
- Large-scale schemes are the primary beneficiaries due to economies of scale.
- Investment outperformance must exceed annual costs to trigger distributions.
- 29 UK locations served by RSM provide a broad view of middle-market pension trends.
FF NEWS TAKE:
The government's push for DB pension surplus flexibility definitely moves the needle, but perhaps not in the way employers hoped. While unlocking billions is attractive for the economy, the increased administrative burdens and regulatory hurdles highlighted by RSM UK suggest that only the largest players will participate. This isn't a free-for-all; it's a highly regulated shift toward managed risk that places a massive premium on high-quality trustee governance.
Companies in this story: RSM UK, The Pensions Regulator
People in this story: Ian Bell