Introduction to Peer Support

The proposal for LGPS specific peer support – derived from the proposals in the Board’s original Good Governance Report and was included in the Government’s Fit for the future consultation and subsequent response issued on 29 May 2025.

Peer support is a constructive and supportive process with the central aim of supporting improvement. It is not an inspection, nor does it award a rating or score. It is delivered from the position of a critical friend to promote sector-led improvement.

Peer support is a learning process that helps funds assess current practice, recognise achievements and identify areas where further improvement or development may be beneficial. Experience from the Local Government Association (LGA) peer challenges show that peers often learn as much from the process as the organisation receiving the support.

Peer support involves exploring a fund’s ambitions, performance and delivery arrangements in a supportive way with fellow peers. This helps build a shared understanding by reflecting on the current position and future direction, and by identifying potential ways forward. There should be no surprises in the process; information is gathered on a non-attributable basis to encourage openness, honesty and sector-led improvement. If an administering authority wants to know how they are doing, who better to ask?

Route into peer support

It is recognised that funds may seek peer support in preparation for an Independent Governance Review (IGR), in response to recommendations arising from an IGR or for other reasons. While the IGR may be one route into peer support, it is not the only route: peer support and the IGR are separate processes, although they may be complementary. For example, peer support may assist a fund in responding to IGR recommendations or may itself be identified as a potential outcome of an IGR.

There are many other reasons for accessing peer support that are not linked to an IGR. It is therefore envisaged that funds may want to self-refer via their LGPS Senior Officer, Pension Committee or Local Pension Board.

Objectives of LGPS Peer Support

The following objectives have been identified for a LGPS peer support offer:

  • To support LGPS administering authorities in strengthening governance arrangements through external peer insight
  • To share, promote and embed good governance practice across the LGPS
  • To facilitate access to an expert network of LGPS peers

Peer support project development

A dedicated working group, made up of fund officers from across England and Wales and a representative from The Pensions Regulator (TPR), has been established to support the Secretariat in developing the model and provide practitioner input. The Secretariat provides project updates to, and receives input from, the Compliance and Reporting Committee (CRC) on progress, risks and next steps, with key decisions then taken by the Board.

Background  

With over 6.68 million LGPS members, of which over 75 per cent are female, the Board is committed to supporting gender equity and ensuring better retirement outcomes for all scheme members. This is why the Board decided in 2023 to explore the Gender Pension Gap in the LGPS and commissioned data from the Government Actuary’s Department (GAD) to assess the difference in the annual pension amounts accrued and in payment for male and female scheme members. The LGPS was the first public sector pension scheme to undertake this type of analysis.  

First report from GAD

The first report from GAD identified a substantial difference between the average LGPS pension benefits currently being built up by male and female scheme members for both active and pensioner scheme members.

The report examined data for members actively contributing to the LGPS (“actives”) and members who were receiving pension payments in respect of their previous employment (“pensioners”) as at 31 March 2020. The mean amounts of pay received, accrued pension and pension in payment for these groups respectively was:

Actives’ pay

Actives’ pay and pension by gender as at 31 March 2020

GenderPercentageMean actual payMean total pension
Female 74%£18,807£3,198
Male26%£27,532£5,416
Gender gap 31.7%41.0%

Pensioners’ pension

Pensioners’ pension in payment by gender as at 31 March 2020

GenderPercentageMean pension in paymentMean partner pension
Female 62%£4,285£1,653 (39% of member)
Male38%£8,466£3,834 (45% of member)
Gender gap 49.4%56.9%

The report showed promising signs that the gap has reduced over time, particularly with the introduction of the CARE scheme and potentially indicates some progress towards equality. But a gap still exists between male and female scheme members and the Board wanted to explore further the reasons for this.

Second report from GAD

The Board commissioned GAD to explore the gender gaps in more depth, focussing on:

  • career patterns – in particular, evidence of recent and past part-time working
  • differences relating to employers or categories of employers
  • comparing the analysis with the LGA’s 2019 gender pay gap report.

This second report set out that essentially there is no simple answer and there seems to be a complex interaction between the types of work women do, their career patterns (in terms of part-time working and gaps in service) and their ability to progress their careers after having taken on childcare or other caring responsibilities.

The report shows, for example, that:

  • part-time working patterns are closely related to gender pension (and pay) gaps for LGPS members. Controlling for differences between men and women in terms of both current and historic part-time working patterns reduces, but does not eliminate, these gender gaps. Possible explanatory factors include length of service and employer differences.
  • pay and pension gender gaps can be attributed to both differences for males and females working for the same employer (‘within employer’) and differences in the proportions of males and females working at higher or lower paying employers (‘between employer’) as well as between different categories of employers.

Current status

When the reports were commissioned there was no settled approach to data and methodological issues that would allow detailed comparisons to be drawn between gender gaps with different public sector pension schemes and or even across the different LGPS funds.

The Board has a working group working on next steps following the GAD reports which reports to the Cost Management, Benefit Design and Administration committee (CMBDA). The working group consists of representatives from LGPS funds, employee and employer representatives, as well as actuaries. The working group has an action plan in place which is looking at identifying possible changes that could be made to the LGPS that might help to reduce levels of inequality.

The Board’s work was recognised in the Access and Fairness consultation in August 2025 which covered changes to the LGPS regulations prompted by the Board’s groundbreaking work.

The latest update on the project can be found in the committee meetings page.

 

In November 2024, the Board elected not to recommission the centralised compliance system which has been managed by Byhiras once the contract ends in August 2026. Instead, the Board has been working with the National LGPS Frameworks team to develop a new framework to enable service users to procure systems offering basic collecting and reporting of cost templates with additional data validation and benchmarking services alongside this if desired. As part of this piece of work, the Board has also taken the opportunity to revise the Code of Transparency, and the updated version has been published.

The FAQs have also been updated to reflect the changes made to the Code which can be found below. It is expected that the new framework will be launched in the Spring of 2026, and the Board will issue communications to relevant stakeholders in support of this which will include further revision to the FAQs next year.

Information

Which managers are signed up to the Code, and thus will be required to use the system?

The list of managers that have signed up to the Code can be found on the Manager list page. This is updated on a regular basis as new managers join.

Those Investment Managers who sign up to the Code will be able to use the Code logo on their marketing literature. Code signatory status demonstrates their commitment to transparent reporting of costs. Institutional investors outside of the LGPS are increasingly recognising the Code as a differentiator in requests for proposal; there is no similar equivalent Code in the UK or internationally. There is no cost to fund managers to sign up to the Code.

What should I do if my manager won’t provide the information or sign up to the Code?

There should be certain requirements as part of the Investment Management Agreement (IMA) you have with your manager on what cost information they are required to provide to you so you can complete your Accounts in line with guidance and this information should be provided to you irrespective of whether the manager has signed up to the Code.

Over time, it is expected that more managers will sign up to the Code and it is now usually a requirement for any mandate tender that applying managers are signed up to the Code. However, there is no requirement for existing managers to sign up to the Code. In these cases, it may be that the information required for the templates is being provided already and / or is provided to other clients in other jurisdictions (e.g. the ILPA template for US Private Equity firms).

It is hoped that all parties involved with the Code and the system (SAB, LGPS funds & pools, existing manager signatories) will encourage those not currently signed up to the Code and system to do so in the short and medium term.

What happens if an Investment Manager doesn’t comply with the Code?

The SAB may revoke use of the Code logo and publicly remove a fund manager from the list on its website at any time if a fund manager is reported by a pension fund (or pool) to be in breach of the Code. The introduction of the system will allow the SAB to monitor and engage with all parties to ensure that the Code is followed.

Freedom of Information Act – what impact will this system have on how we respond to FoI requests?

There is no new information being provided through this system than you will have already been receiving through the manual submission of completed templates to you by your managers. As a result, there does not need to be a change in your approach to responding to FOI requests and with the ultimate public document being the Annual Report and Statement of Accounts, those requesting information could be pointed to that.

Is it fair that the templates consider only costs – not returns or risk?

In assessing investments, LGPS funds will consider risk, return and cost. The specific purpose of the templates is to provide LGPS funds with information on costs. By design, they include very limited information on performance and no information on risk. However, in assessing those costs, funds will take into account the performance delivered and the risks taken.

What should pension funds do with this data from the templates and system?

As well as using the data from the templates in compiling the statement of accounts, clearer presentation of the cost data can be discussed with pension committees and lead to discussion and evaluation for future investment decisions. Understanding cost of ownership is fundamental to good investment governance and better decision making. An important benefit of knowing cost of ownership is an improved negotiating position.

How does the system work for LGPS investment pools?

How does the system work for LGPS investment pools?

LGPS pool companies can be both fund managers and clients and may therefore both provide information to their LGPS fund clients and receive information from their signatory underlying managers through the system. From 1 April 2026, pools will be taking over day to day investment operations from funds in England and Wales. It is expected that pools will be responsible for collection of CTI and ILPA templates for the purpose of cost reporting and will provide this information to their partner funds.

Templates

What mandate types are covered by the templates and the system?

The templates are designed to cover all mandate types other than direct cash and directly held property.

Does a fund manager have to sign up to the Code to use the templates?

In theory, a manager could provide the templates and information without being a Code signatory but it would not be able to benefit from positive publicity associated with being a Code signatory.

What do the templates look like?

The templates that are accepted by the system are the main account template (CTI Main Account Template), the private equity sub-template (CTI Private Equity Template) and the Institutional Limited Partners Association (ILPA) template – relevant for US Private Equity mandates.

Can I adjust or amend the templates?

No – these templates are set by third parties (CTI or ILPA) and so should not be amended. Code signatories have to produce for their clients unamended, correctly completed templates based on the versions released by ILPA & CTI.

What currencies can the templates be completed in?

Templates can be completed in GBP, EUR, USD, JPY, CHF, AUD and CAD.

Funds can then choose the FX rate for conversion based on:

  • Period end: selects the rate on the end date of the period as specified by the template
  • Specified date: selects the specific day the FX rate will apply
  • Average rate: selects an average between two dates within the reporting period. By default, the start and end of the period as specified in the template will be selected.

How frequently will the templates be provided?

Under the Code, templates must be provided at least annually based on either the calendar year or the funds’ financial year (to 31 March). It is also possible to submit on a quarterly basis and managers are encouraged to do so wherever possible. In the instance of unlisted assets data, the Board recommends the submission of templates on a calendar year basis to assist administering authorities who will need data in time for production of annual accounts. The reporting deadline is currently 31 May of each year for the preceding financial year.  

What information will the templates provide?

The templates provide information on three main categories of investment cost: management fees, performance fees and transaction costs.

Does a LGPS fund have to sign up to the platform?

In theory no, but managers will provide the information to funds via the system so it would be surprising if a fund did not want to benefit from the system.

Process

How will I get access to the system?

Pension fund officers should have received an invitation email inviting them to login to the system as primary users (i.e. users who have certain user admin rights for their organisation). These primary users can then add other staff relevant to that pension fund. If you have not received an email, please contact the SAB Secretariat ([email protected]).

Contacts at the investment managers who have signed up to the Code of Transparency should also have received an invitation email inviting them to login to the system. They too will then be able to add other colleagues to the system. Fund managers will then need to set up their clients in the system together with setting out what kind of template will be used for the relevant mandate.

How do I login to the system?

Given the confidential nature and sensitivity of the data in the system, login to the system will be through three-factor authentication – email address, password and validation by third party app, PingID.

Where can I go to get assistance with the system?

For Code and template related queries, please contact the SAB Secretariat. For system related queries, please contact Byhiras.

How will managers be reminded to submit cost data?

From March 2023, managers will receive e-mail reminders of their reporting obligations and the funds and pools will be notified if a manger is late in submitting data. In addition, the system will display any late submissions to managers, funds and the SAB.

How will I be notified that managers have provided data to the system?

From April 2023, funds and pools will receive an e-mail notification once per week of any new reports uploaded by a manager.

When logging in to the system, funds and pools will be able to see straight away the status of any template completion – whether due, submitted, late or submitted late. From the history menu, funds and pools will also be able to see what was submitted and when.

System

Is this system available for all LGPS funds across the UK?

Yes. While the Code of Transparency and procurement of the system has been run by the Scheme Advisory Board (England & Wales), LGPS funds in Scotland and Northern Ireland are also able to benefit from it through a sharing arrangement with the relevant Scheme Advisory Boards – and as allowed for in the terms of the engagement with Byhiras. There will be no further cost to the LGPS funds across the UK for use of this system over the amount they already pay to their respective scheme advisory boards.

What information will the relevant Scheme Advisory Boards be able to see?

The relevant SABs will only be able to see aggregated cost data for the UK. They will be able to see total fees per asset class, average fees per asset class and a scatter line graph of total costs per the universe of anonymised pension funds – as well as fund groupings by small (<£2.5bn), medium (£2.5bn – £5bn), large (£5bn+) and pools.

To monitor and ensure compliance with the Code, the Scheme Advisory Board (E&W) will also be able to see which managers have submitted templates on time and which are late – but critically, it will not be able to see the content of any of those templates.

By when does a manager have to provide the completed template?

The default in the system is 90 days after the relevant period end (whether this has been agreed as quarterly or annually). However, it is possible to reduce this time for upload where agreed between manager and client. A template submission will show as late if submitted after the relevant deadline.

As the system is in its last year of operation, the Board will not be asking for any changes to be made however the updated version of the Code has reduced the timeline for submission of listed assets (public markets) data templates to 60 days, which Code signatories should endeavour to meet going forward.

Does the system validate and / or verify the template submissions from managers?

The system will check that fields have been completed with suitable content (i.e. fraction where fraction needed, cells cross calculate to give a number referenced elsewhere in the template). On submitting the templates, the manager is asked to confirm that the template is fair, clear and not misleading (and are directed to the FCA website for more details on that statement). For full verification, the SAB system would need to have detailed access to all fund data which is not envisaged, although the main Byhiras system can manage that if funds and managers would like to explore that outside the SAB system.

Does the system provide any benchmarking capability?

The SAB system is not intended at this stage to provide any detailed benchmarking. However, funds will be able to see some comparisons of the various cost items against their peer group (small, medium & large) on an anonymised basis – where there are more than five data points for that comparison. SAB is considering whether and how the data could be used for benchmarking purposes, including whether that’s desirable.

Can Byhiras see my data or use my data elsewhere?

In specifying the system, the SAB placed great emphasis on security and confidentiality. The template data held within the compliance system will be separate from any other database held by Byhiras and cannot be shared by Byhiras with any third parties for any purpose.

How do I get more data and more analysis?

While some funds may be doing significantly more with their cost information, the system set up by the SAB is designed to act as a base level from which all funds can develop over time. Funds will be able to share their data with other parties via the system (with their managers’ approvals) such as investment advisers. There is also a more comprehensive system operated by Byhiras which funds and managers are free to discuss separately which is beyond the current system procured by the SAB. There are of course also other service providers of whom funds will be aware.

Will managers be required to provide data to other service providers?

As signatories to the Code, fund managers are only required to provide template data through the system procured by the SAB. While they may agree to provide the data to others, they are not required to do so by the Code.

How are the asset classes in the system decided?

The asset classes in the system are based on the CIPFA classifications as set out in its guidance. The asset classes are:

  1. Active Listed Equity
  2. Passive Listed Equity
  3. Active Listed Fixed Income
  4. Passive Listed Fixed Income
  5. Unlisted Equity
  6. Private Debt
  7. Property
  8. Infrastructure
  9. Multi Asset Funds / Diversified
  10. Growth Funds
  11. Derivatives
  12. Hedge Funds
  13. Other

Can pension funds upload their own internal data to the system to get a combined picture for internally and externally managed positions?

This is something that will be considered as part of the next phase of development of the system.

Can errors in templates be corrected after submission?

Validation rules will apply on template upload. If incorrect information has been entered, the investment manager should re-upload the template, which will replace the version previously uploaded. A version history will record previously uploaded files..

What might the compliance system do in future?

The SAB and Byhiras are exploring the provision of further functionality to be rolled out on a phased basis.

Does the supplier, Byhiras, provide any other services?

Yes, Byhiras provides a solution to transparency and accountability in investments. As its core service, provided to a number of clients, it aggregates data at the most granular level from source, validates the data and enables users to disseminate proprietary information throughout the investment management supply chain. More information on Byhiras can be found on its website: https://byhiras.com.

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Asset managers signed up to the ’Code of Transparency’ are listed below. This is updated as new signatories join. Five LGPS asset pool companies are signatories; Border to Coast Pensions Partnership Limited, Brunel Pension Partnership Limited, LGPS Central Limited, Local Pensions Partnership Investments Ltd and London CIV. Link Fund Solutions, the provider of asset management services to the ACCESS and Wales pools, have also signed up.

LGPS asset managers are encouraged to sign up to the Code to demonstrate (among other things) their commitment to transparent reporting of costs.

Investment Managers

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In 2018, the Financial Conduct Authority (FCA) launched the Institutional Disclosure Working Group (IDWG) following the FCA’s asset management market study as part of the remedies package and noted the success of the LGPS Code.

The FCA wanted to see more consistent and standardised disclosure of costs and charges for institutional investors. It thought that a standardised disclosure template should provide institutional investors with a clearer understanding of the costs and charges for a given fund or mandate. This should allow investors to compare charges between providers and give them a clear expectation of the disclosure they can expect.

In November 2018, the Cost Transparency Initiative (CTI) was launched between the SAB, Pensions UK and the Investment Association and became the organisation taking forward the work of the previous IDWG. For the LGPS funds to have the relevant data to investigate and understand their respective fees and costs, the SAB and the Investment Association developed the templates currently used under the Code.Signatories to the Code are expected to complete the appropriate template. These are either the Cost TI templates which are accepted in a number of currencies or the ILPA template accepted only in US Dollars.

As these templates are set and published by third-party organisations, they should not be changed by those completing them – other than to include the required information. The online system is not able to accept templates which have been changed (e.g. adding new cells, changing names of columns, etc.).

The CTI (Cost Transparency Initiative) is a combined group of the Investment Association, LGPS Scheme Advisory Board (SAB) and Pensions UK (then known as the Pensions and Lifetime Savings Association or PLSA). It has published a range of templates to date and those that are relevant for LGPS cost reporting and Code of Transparency signatories are the Main Account Template or the Private Markets Sub-Template.

The CTI templates list a series of broad headings for reporting costs and expenses and focuses on those areas which should already be available but may not have been supplied previously by asset managers either proactively or in a format easily useable by LGPS funds. Templates may be submitted in either MS Excel or machine-readable format (for the CTI Main Account template).

The system will accept correctly completed CTI templates in six currencies – GBP, EUR, USD, JPY, CHF and AUD. When uploading to the system in non-Sterling currencies, managers can choose the FX rate for conversion based on:

  • Period end: selects the rate on the end date of the period as specified by the template
  • Specified date: selects the specific day the FX rate will apply
  • Average rate: selects an average between two dates within the reporting period. By default, the start and end of the period as specified in the template will be selected.

Templates from the Institute of Limited Partners Association (ILPA) can also be used for private markets data and is mainly designed to be completed in USD. However, the system has a currency field selection on upload so that it can be completed in non-USD currencies as well – GBP, EUR, JPY, CHF and AUD.

As above, when uploading to the system in non-Sterling, managers can choose the FX rate for conversion based on:

  • Period end: selects the rate on the end date of the period as specified by the template
  • Specified date: selects the specific day the FX rate will apply
  • Average rate: selects an average between two dates within the reporting period. By default, the start and end of the period as specified in the template will be selected.

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Those asset managers who sign up to the ’Code of Transparency’ will be listed on the Board website and able to use the Code logo on their marketing literature.  The Code will be voluntary with asset managers encouraged to sign up to it to demonstrate their commitment to transparent reporting of costs.

Investment managers who wish to sign up to the Code should download and return (pdf via email) the compliance letter to the Board secretariat; contact us

Previous versions of the Code are also available from the Board secretariat

LGPS Investment Code of Transparency (“the Code”)

Date of first publication: 18th May 2017

Date of approval by the Scheme Advisory Board of the current version of the Code: 24 November 2025

Definitions

For the purpose of this Code the following definitions shall apply:

Administering Authority

means the administering authority of a pension fund within the LGPS.

Pools

means an asset pool limited by shares and registered in the United Kingdom which is established for purposes consisting of or including managing funds or other assets for which its participating scheme managers are responsible, making and managing investments on behalf of those scheme managers (whether directly or through one or more collective investment vehicles), and whose shareholders consist only of scheme managers

Board

means the Local Government Pension Scheme Advisory Board, England and Wales

Investment Manager

means an investment manager, who has been or wishes to be, appointed by an Administering Authority or Pool in accordance with the Investment Regulations. For the purposes of the Code, Investment Manager may also refer to any LGPS investment pool

Investment Regulations

means The Local Government Pension Scheme (Management and Investment of Funds) Regulations 2016, the Local Government Pension Scheme (Management and Investment of Funds) (Scotland) Regulations 2010, and the Local Government Pension Scheme (Management and Investment of Funds) Regulations (Northern Ireland) 2000 (as from time to time amended or replaced)

LGPS

means the Local Government Pension Schemes for England and Wales, Scotland and Northern Ireland

Template

means the template information form for the relevant investment types provided by the Board as updated from time to time and made available on the Board’s website

Financial year

means the twelve-month period used in the UK for financial reporting purposes running from 1 April to 31 March of the following year

Introduction (A)

  1. The Board is a body established under the Local Government Pension Scheme Regulations 2013. The function of the Board is to provide advice to the Secretary of State on the desirability of making changes to the LGPS. The Board also has the function of providing advice to Administering Authorities and local pension boards in relation to the effective and efficient administration and management of the LGPS and their pension funds. The Board has the power to do anything which is calculated to facilitate, or is conducive or incidental to, the discharge of any of its functions.
  2. The Board continues to support the move toward investment cost transparency and consistency as an important factor in the LGPS being perceived as a value-led and innovative pension scheme. The principle of cost transparency is also relevant for the CIPFA accounting standards issued for inclusion in the statutory annual report and accounts and is included in the government’s investment reform guidance and criteria for LGPS pooling.
  3. To assist LGPS administering authorities in obtaining the more detailed investment fee data they require, the Board worked with key stakeholders including investment managers, CIPFA and LGPS administering authorities to develop the Code. The Board continues to support Cost Transparency across the wider pensions industry as a founder member of the Cost transparency Initiative (CTI)
  4. The Code has also been adopted by the Scottish LGPS and Local Government Pension Scheme (Northern Ireland) (NILGOSC). As a result, the Code refers to both administering authorities who manage day to day investment management operations in Scotland and Northern Ireland (eight in Scotland and one in Northern Ireland) and pools who will be fully managing day to day investment management on behalf of English and Welsh administering authorities from 1 April 2026.
  5. The Administering Authorities, Pools and the Board continue to recognise their obligations pursuant to the Freedom of Information Act (FoIA), Freedom of Information (Scotland) Act (FoISA), and the respective Codes of Practice made under those Acts and will engage with Investment Managers appropriately in that respect.

Application of the Code (B)

6. The Code is a voluntary code and covers the provision of transparent and consistent investment cost and fee information between Investment Managers and Administering Authorities in Scotland and Northern Ireland and the Pools, the investments it manages on behalf of Administering Authorities and Administering Authorities in England Wales.

7. An Investment Manager may sign up to the Code in writing in the form agreed by the Board. By doing so the Investment Manager is demonstrating its commitment to the transparent reporting of investment costs and fees relating to the LGPS to administering authorities.

8. An Investment Manager who signs up to the Code agrees that within a period of six months of signing up to the Code (or such longer period as the Board may in its discretion agree) it will put in place the systems necessary to allow the completion and automatic (i.e. without the client having to make a request) submission of the Template(s) to each Administering Authority or Pool that the Investment Manager is appointed by (whether at the time of signing up to the Code or in the future).

9. Where an asset class is not covered by the template(s) available under the Code, and following confirmation of such by the Board, an investment manager may sign up on the understanding that within a period of six months (or such longer period as the Board may in its discretion agree) it will put in place the systems necessary to allow the completion and automatic (i.e. without the client having to make a request) submission of cost data substantially similar in scope and detail to that covered by existing templates. The exact format of that cost data is to be agreed with each Administering Authority or Pool that the Investment Manager is appointed by (whether at the time of signing up to the Code or in the future). Managers who sign up to the Code under this provision must adopt and make use of relevant Code templates as they become available.

10. The Template(s) must be submitted automatically (i.e. without the client having to make a request) at least each financial year to each Administering Authority or Pool and to any independent third party or parties appointed by the Board in accordance with paragraphs 11 to 15. Administering Authorities or Pools may also request such submissions on a calendar year, specified 12 monthly, quarterly or semi-annual basis if so agreed by Investment Managers and Administering Authorities or Pools.

11. The Template(s) covered by this Code are those within the framework published from time to time by the Cost Transparency Initiative (CTI). Investment Managers regulated by parties other than UK regulatory authorities may also complete the Institutional Limited Partner Association (ILPA) template.

12. Templates should be provided within 60 days of the end of the desired reporting period for listed assets. For unlisted assets, this should be provided within 90 days. In instances where templates are not provided to the client, i.e. Administering Authority or the Pool, on time, a satisfactory explanation must be provided to the client along with a proposed timeline for submission. Where an Investment Manager who signs up to the Code invests through further fund managers (a fund of funds or multi-manager model), it will also seek the same cost information it is required to provide from its underlying managers to enable the full reporting of costs incurred (both direct and indirect) to the LGPS Administering Authority or Pool.

13. The Investment Manager will not vary the Templates except with the written agreement of the Board and the relevant Administering Authority or Pool.

14. Administering Authorities or Pools should make arrangements to ensure that they have a means of collecting and validating data from the templates, this might include appointing an independent third party/parties either via the National LGPS Frameworks or via internal procurement routes. Administering Authorities or Pools may also appoint a third party/parties to assist with additional data services such as benchmarking and analysis of investment cost data from templates.

15. The Board may appoint one or more independent third party / parties to assess compliance with the Code by Investment Managers. The Investment Manager shall co-operate with the Board or appointed third party / parties and provide such information and explanations as the third party / parties may reasonably require within a reasonable period of request.

16. The third party or parties shall report the findings of any analysis or compliance check direct to the Board, including any recommended actions or improvements. The Investment Manager shall co-operate and work with the Board to address and implement any recommended actions or improvements.

17. The Investment Manager may, subject to any overarching legal or reporting requirements, require an Administering Authority or Pool to sign up to a reasonable confidentiality agreement not to disclose the information contained in the Template to any third parties (excluding any third party appointed by the Board for the purposes detailed at Paragraphs 15).

18. The Board agrees that when an Investment Manager signs up to the Code in the agreed form it will, as soon as reasonably practicable, list the Investment Manager on its website and allow the Investment Manager to use the Code’s logo on its marketing literature in accordance with the Code Logo Use and Guidance (available from the Board website and amended from time to time). The Code Logo Use and Guidance can be downloaded from the Board website.

19. The Board owns the Code logo and will retain all intellectual property rights and any other rights in the Code logo. An Investment Manager will not acquire any rights, title or interest in the Code logo and will not use the Code logo except as expressly specified in the Code and the Code Logo Use and Guidelines.

20. An Investment Manager will be permitted to use the Code logo on a non-exclusive basis to communicate their compliance with the Code. The Code logo will convey to stakeholders that the Investment Manager is compliant with the Code and committed to the transparent reporting of LGPS investment costs and fees.

21. An Investment Manager which has signed up to the Code will not use the Code logo for any other purpose nor for the benefit of any other person and will not alter or change the Code logo in any way – ownership of any modifications in the Code logo will vest in the Board.

22. The Board may revoke use of the Code logo and remove an Investment Manager from the list on its website at any time (that is, to remove an Investment Managers Code signatory status), if an Investment Manager is reported by an Administering Authority or Pool, or considered by the Board, to be in breach of the Code. The revocation of a signatory’s status would only occur after warning and giving the Investment Manager reasonable time to achieve compliance.

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The SAB Cost Transparency, Compliance and Validation System can be found here

Background

As signatories to the Code, investment managers are required to complete and submit the template for the relevant mandate (without request) to their LGPS clients on either an annual or quarterly basis as agreed with their client. In order to streamline the process and make it more widely available, the SAB has procured a system to:

  • Be capable of accepting and storing template data
  • Check the timeliness of data submission and report late returns
  • Ensure that template data is signed off by managers as ‘fair, clear and not misleading’

As well as ensuring compliance with the Code the system can be used by LGPS clients to:

  • Replace the existing excel format templates provided to them by managers
  • View a set of onscreen reporting and comparison tools showing that fund’s data against a similar sized group of funds
  • Give permission to other LGPS clients or trusted third parties (e.g. their investment advisor) to access and export their template data
  • Provide a historical record over time, storing the submitted templates

In specifying the compliance system, the SAB placed great emphasis on security and confidentiality. The template data held within the system will be separate from any other database held by Byhiras and cannot be shared by Byhiras with any third parties for any purpose.

This system went live on 1 April 2020. The Board may publish aggregate totals or averages from the system as part of the scheme annual report. Such reporting will not identify any data at the fund, pool, manager or mandate level.

Purpose

The purpose of the compliance system is to provide cost effective template data collection and LGPS Code compliance checking, including reporting and data comparison facilities.

The system is paid for from within the Board budget and funded by the levy. LGPS clients and investment managers have access to the system free of any further charge though further enhancements will be discussed with all relevant parties as to possible cost sharing.

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Background

The Good Governance project was instigated by the Board to examine the effectiveness of LGPS governance models and consider enhancements to further strengthen governance standards across the LGPS. Its aim is to ensure consistent, high-quality governance and administration across the scheme.

While preliminary work occurred earlier, the project was initiated in 2019 with the Board undertaking a survey of administering authorities and then appointing Hymans Robertson to lead the review and propose improvements.

The project compromised three phases from 2019 to 2021:

  • Phase I: Initial research and stakeholder engagement and draft report published.
  • Phase II: The Phase II report from Hymans Robertson was published following the outcome of findings from working groups. 
  • Phase III: Final report and action plan for implementation, including proposed regulatory changes and best practice published.

Recommendations

Following the final report, the Board created an action plan and wrote to the (then) Minister with a formal request to MHCLG and other bodies to implement the recommendations from the project together with an action plan for the Board which were either dependant on or regardless of the outcome of those requests.

Implementation

  • The action plan contained proposals to implement the changes mainly through statutory guidance and some regulatory amendments.
  • The Board and the Compliance and Reporting Committee set up working groups to refine proposals and support implementation.
  • Collaboration between the Department, Board, and stakeholders

Current status

  • The Board welcomed the long-awaited progress of its Good Governance recommendations when the government launched the Fit for the Future consultation in November 2024 and the subsequent government response in May 2025. However, the Board in its response to the consultation noted that the consultation was fairly high-level and there were some missing key recommendations that featured in the Board’s original action plan.
  • The Board has a working group under the Compliance and Reporting Committee which has met regularly to discuss the implementation of the Good Governance recommendations as a result of the Fit for the Future consultation. The progress of the working group can be found in the Compliance and Reporting committee reports.
  • In November 2025, the government launched a technical consultation seeking views on 2 draft statutory instruments including whether these effectively deliver the policy proposals set out in the government’s response to the earlier Fit for the Future consultation which also covered governance.
  • In December 2025, the government launched a closed consultation on the draft statutory guidance accompanying the revised regulations. The Board’s response to both consultations are on the responses to consultations page.

Key documents

Background

The Board is keen that the LGPS is seen as a value led and innovative scheme and investment fee transparency between asset managers and their clients forms part of this goal.

Cost transparency is also incorporated into CIPFA’s accounting standards that apply to LGPS administering authorities and cost date much be included in their statutory annual report and accounts, as well as being included in the government’s criteria for pooling investments.

Investment costs are a complex area which pension committees and fund officers need to understand to ensure they are getting value for money from fund investments. The LGPS Code of Transparency (CoT, the Code) helps LGPS clients i.e funds and pools gather cost information in a consistent format. Cost information must always be viewed in the context of risk and return, and should form part of any overall value for money assessment

 The LGPS Code of Transparency covering investment management fees and costs was first developed and approved by the Board in May 2017. The current Code, which was updated in 2025, can be found using the menu at the bottom of this page.

From its outset, the Code of Transparency was an LGPS Advisory Board (England and Wales) initiative. However, since its launch, the Scottish Scheme Advisory Board and Scottish LGPS and LGPS (Northern Ireland) clients have been included at their request.

Fund managers to the LGPS are encouraged to sign up to this Code and as at December 2025, there were over 170 signatory firms.

Code signatories are able to use the CoT logo to confirm their signatory status and can use it in marketing to other possible clients. Most LGPS funds and pools now require bidding managers to be signed up to the Code. Code signatories can request the logo details and colour palette from the SAB Secretariat.

A set of frequently asked questions that have been raised by investment managers and LGPS clients is available here on the FAQs page.

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Background

Over a decade ago, public sector pension schemes were reformed building on the findings of the Independent Public Service Pensions Commission, chaired by Lord Hutton. The Commission conducted a fundamental structural review of public service pension provision.

The Coalition Government accepted the recommendations of the Commission’s final report as the basis for negotiation with the trade unions and legislated in the Public Service Pensions Act 2013 for a framework for new public service pension schemes that were introduced from April 2015.

Key changes for the reformed schemes were moving from a final salary to a career average basis and linking the Normal Pension Age in the scheme to State Pension Age. In the course of negotiations on the reforms, the then Chief Secretary to the Treasury, Danny Alexander, said that the reformed schemes should endure for 25 years.

The need to control future spending

It was also agreed that there should be a mechanism to control future spending on public service pensions, by setting a fixed proportion of pensionable pay that public service employers would contribute to the schemes in the long term. If this cost were exceeded (or fell beyond certain minimum parameters), then the Government should consult on how to bring those costs back within the agreed parameters, with an automatic default to be applied if agreement could not be reached.

To achieve this, the government established cost control mechanisms which calculate the cost of providing scheme benefits. This mechanism is generally applied to those benefits that have been accrued since the career average reforms took effect in April 2014.

The cost control processes

In LGPS there are two processes that run alongside each other to deliver this aim.

The first is a HMT-led process that was originally designed only to control changes in “member costs” (those relating to assumptions about the profile of scheme members) and excluded changes in “employer costs” (those relating to assumptions that are financial or technical in nature). However, following a consultation in 2021, the Government introduced a further check to link this process to changes in the long-term economic outlook. This meant that there would be a higher bar for benefit increases to be awarded if the country’s long-term economic outlook worsened.

The LGPS Regulations 2013 state that the employer cost cap for the Scheme under this process is 14.6% of pensionable earnings (excluding member contributions). Actuarial assumptions to allow the calculation of this are set out in HM Treasury Directions.

One of the Board’s statutory duties, under the 2013 regulations, is to introduce and maintain its own process to examine costs in the scheme alongside the process introduced by HM Treasury. The aim of this process is to provide greater control over employer contribution rates and the actuarial assumptions for this are decided by the SAB. The 2013 Regulations set the agreed target future service rate for the LGPS in England and Wales, at 19.5% of payroll (including member contributions).

Further information

Here are some key documents relating to how the cost control process has been running to date.

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