The National Association of Pension Funds (NAPF) and Society of Pension Consultants (SPC) have published their responses to the consultation on the draft regulations that aim to simplify the statutory internal dispute resolution procedure (IDRP) regime. For background information on the consultation, see Legal update, DWP consults on draft IDRP amendment regulations.

The NAPF highlights that the proposed statutory obligation to give applicants details of the Pensions Advisory Service may become out of date, given possible future legislative changes in the area of providing generic financial advice. Further, the NAPF suggests this duty should only apply at the initial stages of the IDRP. By contrast, the SPC suggests that the duty should apply when applicants receive final decisions under the IDRP.

The SPC also queries whether there will be a statutory requirement on schemes to tell their members if they implement a single-stage IDRP following enactment of the regulations. Additionally, the SPC believes that proposed regulation 2(1), which requires applicants to be given details of the Pensions Ombudsman when receiving notification of an IDRP decision, should be updated to cover schemes that continue with a two-stage IDRP. Otherwise, applicants may approach the Ombudsman's office before receiving a second stage decision, in circumstances where the Ombudsman will not have jurisdiction to investigate.

See Consultation on draft regulations, NAPF, December 2007 and Letter from SPC to DWP, 19 December 2007.