The Society of Pension Professionals (SPP) has responded to the current DWP consultation on Retirement Collective Defined Contribution (CDC) schemes. The public consultation closes on Thursday 4th December 2025.
The SPP response acknowledges that there are arguments for and against Retirement CDC schemes being made available in the retail environment; strongly supports the introduction of a ‘cohorting’ approach; and agrees that there is a strong case for a charge cap to be introduced.
The response also urges the government to “…work at pace on the development of this framework…” warning that it would be “…a significant missed opportunity if the Government were to introduce their Guided Retirement requirements on DC schemes in advance of Retirement CDC schemes being made available.”
The submission suggests that the timescales for authorising Retirement CDC schemes should be accelerated to dovetail with the introduction of the Guided Retirement duty, which is expected to come into force in early 2027.
Keith McInally, Chair of the SPP’s CDC Committee, said;
“The SPP is pleased that the government is moving quickly on Retirement CDC policy and we very much welcome the policy framework that is being proposed.
However, there remains a substantial timing challenge relating to Guided Retirement. If the Government were to introduce their Guided Retirement requirements on DC schemes in advance of Retirement CDC being made available, schemes may not have much appetite to revisit their Guided Retirement options in the short term.
Our response suggests some practical solutions to this challenge and we look forward to working with government to ensure savers don’t miss out.”

















