Performance update on Scottish Public Pensions Agency priorities: FOI release

Information requested

A performance update on the following SPPA priorities:

• Progressing legislative work
• Meeting regulatory deadlines

Response

Progressing Legislative Work

The statement, “Progress our legislative work, specifically bringing closure to any outstanding work in relation to McCloud Remedy, so that we can deliver on this responsibility to our members”, reflects one of SPPA’s key business priorities for 2025/26. This objective has been formally included in our 2025/26 Annual Business Plan, as we were unable to fully meet all legislative deadlines within the 2024/25 business year under the McCloud Remedy programme.

The original statutory deadline, as set out in the Public Service Pensions and Judicial Offices Act 2022, was 1 April 2025. By this date, all eligible members were to receive their Remediable Service Statement (RSS) and be offered their Deferred Choice Underpin (DCU) options. However, Section 29(10)(b) of the Act allows scheme managers to extend this deadline where reasonable, based on the circumstances of particular members or member groups.

SPPA has exercised this discretion due to the scale and complexity of delivering the remedy across four large public service pension schemes, and the need to tailor communications and processes for active, deferred, and pensioner members. This was formally acknowledged in the NHS Circular 2025/05, which outlines revised delivery timelines and the rationale for delays. 2025-05_NHS_Circular_McCloud_Remedy_administration_–_Remediable_Service_Statements.pdf

The inclusion of this legislative priority in our 2025/26 plan is not an indication of lack of progress, but rather a reflection of our commitment to completing the remaining work responsibly and transparently.

Additionally, the 2024/25 Annual Business Plan included the priority: “Effectively support members, employers and colleagues through Remedy 2015 changes”. Progress against this will be reported in our 2024/25 Annual Report and Accounts (ARA), expected to be published in October/November 2025, following review by Audit Scotland.

For further detail, including updated timelines and delivery plans, please refer to the NHS Circular 2025/05 titled “McCloud Remedy Administration – Remediable Service Statements”, published on 15 April 2025. 2025-05_NHS_Circular_McCloud_Remedy_administration_–_Remediable_Service_Statements.pdf

Meeting Regulatory Deadlines

“Meeting all regulatory deadlines for the 2015 Remedy” was a key performance indicator (KPI) outlined in SPPA’s 2023/24 annual business plan. Performance against this KPI was reported in the SPPA Annual Report and Accounts 2023/24, which was published on the agency’s website in December 2024. SPPA_Annual_Report_And_Accounts_2023_24.pdf

Please see an extract from the ARA document;
KPI: meet all of our regulatory deadlines for 2015 Remedy. We upgraded Police and Fire pension systems to produce dual calculations by October 2023. We took steps to protect NHS and Teachers members by moving them directly to legacy schemes at that time. We are working towards the March 2025 regulatory deadline for provision of dual calculations to all members. This is dependent on third party software providers, and our 2015 Remedy program is overseeing their delivery. Due to delays in legislation, we were unable to meet our commitment to provide members subject to immediate detriment with options by October 2023. This also impacted our commitments to introduce a facility to deliver dual Annual Benefits Statements and commence rectification early in 2024.

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