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Article | Benefits Hot Topics

PPF Levies 2023-24 and beyond

By Joanne Shepard and Mark Dowsey | September 29, 2022

The PPF has published its draft levy rules for 2023-24, proposing a reduction in total levy from £390m to £200m with around 96% of schemes expected to have a lower levy.
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The Pension Protection Fund has today published its consultation for the 2023-24 levy (to be invoiced in 2023). Citing the continued improvement in its financial resilience, the PPF expects to collect £200m, almost half of that estimated for 2022-23 (£390m), with around 96% of schemes predicted to see a levy reduction. Exceptions are those where underfunding has increased significantly.

Schemes in lower levy bands (1 to 3) are likely to see smaller reductions than those in bands 4 to 10, although some schemes in levy band 10 will see a slightly smaller reduction if their levy has previously been capped at 0.25% of s179 liabilities. The PPF does not expect to apply the cap to any schemes in 2023-24.

What are the proposals?

  • The risk-based levy factor reduced by 23% from 0.48 to 0.37.
  • The scheme-based levy multiplier reduced by 10% from 0.0021% to 0.0019%.
  • Levy rates for levy bands 2-10 reduced, halving the band-to-band increase in levy rate.
  • Risk-based levy cap remains at 0.25% of scheme liabilities (and the short-term limit on increases in the risk-based levy removed as previously indicated), though the PPF does not expect any schemes to have a capped risk-based levy.
  • Updated asset stresses to reflect the increased number of asset classes expected to be collected in the 2023 Scheme Returns, with the main change being a reduction to the stress on UK equities.
  • A change to Scorecard 6 (small group companies): the replacement value for Debtors where this variable is not available amended to 5.64.

The PPF describes its 2023-24 proposals as a “first step toward… a lower and simpler levy”. As well as improvements to the PPF’s funding position, the downward trend reflects the PPF’s assessment that future claims will be lower because of improvements in schemes’ funding positions.

The PPF expects the reduction in the levy from £390m in 2022-23 to £200m in 2023-24 to be broken down approximately as:

  • Changes in market conditions and other data: £70m reduction
  • Changes to levy band insolvency risk: £60m reduction
  • Changes to risk-based levy factor and scheme-based levy multiplier: £60m.

Longer-term proposals

Although the PPF wishes to reduce future levies significantly – recognising that its improving financial resilience raises the prospect of building up a surplus if levies are higher than necessary – it is concerned that existing legislation fetters its ability to increase levies in the face of an unforeseen change in fortunes or significant increase in claims.

The PPF considers that, if it needed to return to charging a materially higher aggregate levy, the most likely cause would be a decline in the PPF’s funding, rather than a general rise in the risk the PPF covers.

The PPF has identified four key design principles:

  • Increased flexibility in the amount of the levy collected (including permitting a zero levy)
  • Increased flexibility to charge on the basis of the size of the scheme (scheme-based levy)
  • Rebalancing the risk-based levy to emphasise underfunding and a lesser focus on employer insolvency
  • Openness to different approaches to how the levy is calculated depending on scheme size.

The deadline for responding to the consultation on next year’s levy is 5pm on 10 November 2022.

Contacts


Joanne Shepard
Director
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