Member

The Government’s firm view is that any exemptions to the scale requirement should be limited to enduring scheme design and purpose. We believe they should be tightly drawn to deliver the policy intent, but Amendment 37B would enable a regulator to exempt any size of scheme for an undefined period from the scale requirement, where there is no reasonable prospect of improved outcomes through consolidation or that innovation delivers good member outcomes. I recognise that this amendment appears to have more focus on members. Unfortunately, the nebulous nature and number of the tests may mean that it could, in practice, still open the floodgates to all schemes in scope and deny members better outcomes. The amendment risks delivery of the policy intent because it seems to offer wide and ill-defined exemptions to any scheme within scope of the scale measures.