Statutory framework Investment of LGPS pension funds in
England and Wales is governed by the Local Government Pension Scheme (Management and Investment of Funds) Regulations 2016, which require each administering authority to maintain and publish an Investment Strategy Statement and to have regard to statutory guidance when doing so. The government first set out criteria for pooling assets in November 2015, inviting proposals for collective investment vehicles to achieve economies of scale and improved access to certain asset classes.
Policy evolution and current requirements Following consultation on “next steps” in 2023, the government issued its Fit for the future response in May 2025. It confirms minimum standards to be mandated in legislation, including that administering authorities delegate implementation of their investment strategy to their pool, take their principal investment advice from the pool, ensure the pool is an
FCA-authorised investment management company with capacity to implement strategy, transfer all investments to the management of the pool, and develop capability for
due diligence and management of local investments. The response also sets expectations for plans and reporting on local investment, and for strengthened governance and training, with independent reviews and clearer transparency at pool level. It indicates a March 2026 point by which all assets should be under pool management, while allowing for implementation choices between pooled vehicles and other arrangements decided by the pool in the collective interests of partner funds.
Pools and operating models Eight asset pools operate in England and Wales. Operating models vary. Some pools are FCA-authorised managers and act as operator/AIFM of an
Authorised contractual scheme, while others appoint an external FCA-authorised operator. Examples include London CIV and LGPS Central as authorised managers, and Wales Pension Partnership and ACCESS appointing Waystone as the operator for their ACS vehicle.
Implementation scale and savings Government and Scheme Advisory Board data record that , about 45% of LGPS assets in England and Wales were invested through pool vehicles, with a further 27% managed by pools outside those vehicles. Taken together, around 72% of assets were under pool management at that date. The policy case for pooling emphasises net savings and better access to private markets. Reporting is being standardised so that funds disclose the proportion pooled or under pool management,
asset allocation, and net savings in annual reports and in their investment strategy statements.
Investment policy: private markets and local or UK investment Reforms since 2023 aim to widen access to private markets and improve transparency of costs and outcomes, while leaving asset selection to the pool and partner funds within fiduciary duties. The 2025 response expects administering authorities to set out their approach to local investment in the strategy statement, including a target range, to work with
strategic authorities to identify opportunities, and to report annually on local investment and its impact. Pools are expected to have the capability to carry out due diligence and make final investment decisions on such projects. Coverage in the national press has highlighted sector support and objections, particularly around timelines and the prospect of further consolidation.
Governance, skills and transparency Alongside pooling, the 2025 response sets measures on governance and capability that include knowledge and skills for committee members, a senior LGPS officer role, a published governance and training strategy and an administration strategy, regular independent reviews, and greater transparency of pool boards. Funds and pools are also expected to meet the expectations in
The Pensions Regulator’s General Code regarding effective systems of governance and internal controls.
Climate and stewardship reporting In 2022 the government consulted on proposals to require administering authorities in England and Wales to assess, manage and report climate-related risks in line with the
TCFD framework, and many funds and pools have published TCFD-style reports while awaiting final pensions-specific regulations or guidance. Government also issued TCFD-aligned disclosure guidance for the UK public sector in July 2025, which some bodies may apply or follow in part alongside pensions-specific requirements.
Pools and indicative size The landscape and sizes change as funds transition between pools. The figures below are recent public statements by the pools or official summaries. Each is dated and sourced. == Devolved nations ==