18 July 2025

BB CIRCULAR – 011-2025

To: All Branch Secretaries CC: Branch Council Admin

Dear BB Secretaries,

Please see the attached NPCC response to a staff association request for contribution adjustments owed by members to be paid by instalments. The Scottish Government have allowed the payment of monies owed by instalment.

PFEW are disappointed by their response and with their response to our extensive efforts to deal with the continued unfairness in applying interest on contributions owed. In the latest NPCC bulletin they again reiterated that interest should still be applied to officers who have not received an RSS. A regulatory deadline has been breached, and our members and former members are being charged interest on contribution adjustments that they cannot pay as forces have failed to provide them with details of what is owed. That is not acceptable, and Chief Constables should be lobbied to use the ability they have to waive or freeze interest.

Unfortunately, as can be seen by the response to our request for an instalment plan lobbying may well be met with intransigence.

The Economic Secretary to the Treasury, Emma Reynolds MP in a recent parliamentary debate when asked about outstanding remedy issues stated, ‘I encourage scheme managers to take every step possible to resolve those cases as quickly as possible and to prioritise cases where individuals may be in particular ne

You will know how your force is doing in regard to taking every step possible to get remedy done but we are still seeing evidence that some forces are not approaching it with sufficient rigour or support for affected officers, retirees and beneficiaries. We need to hold forces to account and as such need to regularly speak with scheme managers and their delegated senior leaders to ensure progress is being made.

Where data issues are causing delays either internal or external then we need to be asking if that data is ever going to be available and if it is not then forces are going to need to make assumptions and that should not result in members being disadvantaged.

If there are any particular issues you would like to raise with PFEW then please contact Paul Turpin directly and he will collate and advise.

Yours sincerely,

National Secretary (Elect) John Partington

3 July 2025

Dear Shabir,

Repayment of underpaid contributions by instalments

I am writing in response to your letter of 3 June 2025 on behalf of the staff associations regarding a request that NPCC reconsider its position as to the repayment of underpaid contributions by instalments.

You will be aware that the Police and Fire SABs were involved in several engagement sessions to talk through the policy issues of remedy with the Home Office during 2022 and that one of these topics for discussion was about contribution adjustments which included the option of periodical contributions. This was prior to the Home Office launching their consultation on the retrospective McCloud remedy in February 2023.

The view of NPCC as outlined in our consultation response was that periodical contributions would be impossible to audit, come at significant cost and would be unwieldy to administrate. This is still the view of NPCC, and the experience of remedy has shown this that this would indeed have been a significant issue for forces to manage.

The reasons why NPCC hold this view are as follows:

• Experience of the Fire sector when they introduced the Modified Fire Scheme in 2014 and

permitted members to pay by instalments over a 10-year period.

• The same process could not be applied to both active and deferred members, unless all

payments were made by Standing Order or Direct Debit. But these types of payments are

unwieldy to manage on a monthly basis, members could cease payments and refuse to set

them up again, there may be insufficient funds to collect the payment, or the account

could be closed.

• Members circumstances change over time, issues such as sickness, career breaks,

divorce, other personal financial issues could all mean that members may want to stop

paying the periodical payments before the end of the term.

• Forces are not banks, or debt recovery agencies and they would need to be both to be able to effectively administrate periodical payments.

• Forces have been overwhelmed with the amount of additional work they have been

required to do because of remedy, periodical payments would require entirely new

processes and significant additional resources to ensure that robust recording,

recalculations of amounts due, as well as accurate reporting and accounting and debt

recovery actions were all in place.

It is NPCC’s view therefore that the options that are available to members are the most suitable options, not just for members but also for forces.

• Members do not have to make any contribution adjustments until they reach retirement

when the amount due can be deducted from their commutation lump sum. The interest

that accrues simply represents the time value of money and reflects the fact that protected

members of legacy schemes paid the correct contribution rate at the time, whereas taper

and unprotected members paid a different rate.

• Additionally, a member has the choice on an annual basis before they retire, to settle their contribution adjustment within three months of receiving their Annual Benefit Statement Remediable Service Statement (ABS-RSS).

• Alternatively, there is absolutely nothing stopping a member setting up their own savings

account, with the same or better interest rate that is provided by NS&I, into which they

could make their own periodical contributions. This means that they will have access to the

funds should it be required and they will benefit from the interest accrued.

In relation to the Duty of Candour, I believe that this, the whole basis of the payment of contribution rate differences and interest is to provide fairness of treatment across the different groups of members throughout the remedy period, such that all officers can be sure that they are being treated on the same basis in respect of contributions.

Yours sincerely

Claire Neale

NPCC Head of Police Pensions