Additional Voluntary Contributions (AVCs)

Trustees of Defined Benefit (DB) pension schemes have a legal requirement to ensure the appropriateness of AVC arrangements. Overlooking AVCs not only risks regulatory sanction but could have a negative impact on retirement outcomes for members of the scheme.
The General Code of Practice came in to force in March 2024 replacing a number of older Codes of Practice including the DC Code of Practice.  The General Code does not specifically call out AVCs as it did in the old DC Code.  Therefore, Trustees should now consider they apply their effective system of governance across the whole pension scheme, which means including AVCs.

Meeting statutory duties

Trustees are obliged under trust law and the requirements of the Pensions Acts 1995 and 2004 to exercise a duty of care in relation to the investment of AVC assets. This includes ensuring:

  • They are offering a competitive investment product, in terms of the provider(s), their services and charges;
  • That there is a suitable range of investment options; and
  • That the investment managers are suitable

The DB pension scheme’s Statement of Investment Principles (SIP) should also cover what the Trustees are doing in relation to their AVCs.

An increased focus on AVCs in DB pension schemes

With increased scrutiny of governance arrangements through the General Code, Pension Dashboards on the horizon, changes to pension taxation limits, well documented service issues delivered by some AVC providers, and many Trustees looking at end game planning, it is more critical than ever that Trustees add a review of their AVC arrangements to their business planning, if they haven’t already.  

Reviewing AVCs isn’t just about monitoring investment performance either. Data quality, orphaned AVC members, opaque with-profits policies with misunderstood terms and conditions, cyber security, poor administration experiences are just some of the things Trustees need to incorporate to achieve good retirement outcomes for their members.


How we can help

Mercer has a dedicated AVC team with extensive knowledge and a deep understanding of the AVC provider market, we can provide services to help Trustees meet their strategic objectives and fulfil their statutory obligations.

Training

Our sessions provide you and your Trustee Board with what you need to know about AVCs, your legal obligations and the options available. They are engaging, easy to understand and delivered by one of our experts.

Reports

We offer a range of reports depending on your needs from Performance reports to comprehensive Governance reports, and for Trustees with end game planning on their radar we can provide End game planning reports.  AVC reports that Mercer are able to provide include:
  • 1. Performance Report

    This is a basic performance monitoring report with performance tables and member fees only. No members funds or assets provided. This is suitable for Unit-Linked only AVC policies.
  • 2. Performance Plus Report

    This is the minimum report available if With-Profits policies are included. This is a basic performance monitoring report with performance tables and member fees. It will also include the number of members and asset values. It can be done for Unit-Linked only AVCs if this additional level of detail is desired.
  • 3. Governance Report

    This report covers member demographics, performance, member fees, With-Profits contract terms, underlying performance and bonus rates, fees, provider commentary, Trustee duties, options for Trustees, case study, recommendations and commentary throughout.  This covers all the necessary governance reporting for Trustees.
  • 4. Endgame Planning Report

    This report covers everything included in the Governance report and also covers buy-in / buy-out considerations with respect to DC / AVCs.  This includes recommended planning actions to secure the DC / AVC assets outside of the scheme so that the Trustees can take appropriate actions as part of the journey planning. Whilst this report does not include regulated advice, we would expect this to follow on from trustee agreement to our proposals for securing DC / AVCs outside of the current trust.

Member Communications

To ensure your members remain engaged with their AVC investments, and feel empowered to make informed choices, you should communicate the findings of the reports to them. To assist, we have developed a suite of engaging templates which we can customise to meet your needs and the needs of your members.

Consolidation and discharge

Whether it’s about consolidating providers, harmonisation or investment changes, our AVC team experts provide regulated advice and manage change projects from start to finish.

Our AVC team supports you with your endgame planning as part of buy-in and buyout projects. By engaging with AVC providers and understanding the various buyout AVC solutions available, we are well-equipped to navigate the complexities surrounding AVC policy guarantees, including With-Profit funds and tax-free cash linkages.

While demands on Trustees are wide and varied, doing nothing about your AVC arrangements should not be an option. We can help you take a proportionate and pragmatic approach to help you deliver the best value to your members and meet your statutory obligations.

Operational efficiency

Our dedicated AVC team collaborates closely with AVC providers, fostering strong senior-level relationships that enable agile escalation and timely updates on critical issues – for example cyber security, dashboards, service levels and strategy.  Our solutions leverage bulk processes and, where possible, utilise automation to deliver cost-effective services to our clients.

Next steps