Item 11 - West Dunbartonshire Council Policy Statement - Local Government Pension Scheme (Scotland) Regulations 2018
West Dunbartonshire Council · 12 November 2025
Back to Corporate Services Committee — 12 November 2025 and its agenda
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WEST DUNBARTONSHIRE COUNCIL Report by Chief Officer – People & Technology Corporate Services Committee – 12 November 2025 ___________________________________________________________________ Subject: West Dunbartonshire Council Policy Statement - Local Government Pension Scheme (Scotland) Regulations 2018 1. Purpose 1.1 The purpose of this report is to provide details of the review and summary of changes in relation to the Local Government Pension Scheme (Scotland) Regulations 2018 employer discretions. 2. Recommendations 2.1 It is recommended that the Committee notes the structural improvements and policy clarifications introduced in the 2025 draft and endorses the updated format for future use. 3. Background 3.1 This policy has been submitted for consideration to ensure appropriate scrutiny of the Council’s discretions in relation to the LGPS provisions following the letter (8 September 2025) from the Accounts Commission outlining their consideration of a report from the Controller of Audit (under powers in s102 (1) of the Local Government (Scotland) Act 1973) in relation to the scrutiny, governance and transparency of decision making of exit packages of senior officers in Glasgow City Council. 3.2 The findings highlight that where decisions around restructuring and exit packages are being taken, councils must ensure there is clear evidence of effective governance, independent scrutiny, and value for money, as well as robust and transparent record keeping. A report outlining the council’s position on each of these areas will be remitted to the Audit Committee on 10 December 2025. 4. Main Issues 4.1 The Local Government Pension Scheme (LGPS) Discretions Policy Statement is reviewed periodically. The 2024 version was structured according to each set of regulations, separately into tables. The revised 2025 draft consolidates all discretions into a numbered list, organised by topic and supported by clear headings and internal commentary. ITEM 11
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4.2 Key changes include: Consolidation of discretions into a single numbered list (71 items) - laid out in subject order (alphabetically) for ease of reference; Introduction of 'For noting only' labels for provisions the Council are not required to set out in policy but included for oversight; Discretions with policy statements unchanged from previously approved May 2024 version are marked as ‘No Change’; Addition of discretions related to Compensatory Added Years (CAYs), gratuities, and deferred retirement. Clarification added in respect of existing policies, such as Ill Health Gratuity and Double Entitlement; and Inclusion of internal comments for transparency and explanation. 4.3 It is worthy of noting that most existing policy statements remain unchanged, including contribution rates, aggregation deadlines, and forfeiture provisions. 5. People Implications 5.1 There are no direct people implications associated with this report. 5.2 The new format will provide ease of reference and understanding for employees and managers in respect of responsibilities when considering matters under their discretion. 5.3 There are no additional implications for the additional discretions as outlined in 4.2 as current practice in line with Strathclyde Pension Fund’s processes and procedures has been noted. 6. Financial and Procurement Implications 6.1 There are no financial or procurement implications arising from this report and policy. The policy provides robust guidance and scrutiny in relation to the application of pension discretion provisions. 7 Risk Analysis 7.1 There are no risks associated with the Pension Discretions Policy as it is providing clear governance and scrutiny around the application of the pension discretion provisions. 7.2 Failure to update and clarify policy statements could lead to misinterpretation or inconsistent application of discretions. This is mitigated by periodic review and updating committee.
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8. Equalities Impact Assessment (EIA) 8.1 Discretions available under the LGPS are determined by Regulation, with employers thereafter determining whether or not to exercise specific discretions. 8.2 A number of discretions are age specific and apply to those employees aged 55 (age 50 for protected members) or over. While this is a requirement of the regulations and has specific exemption under the Equality Act 2010, age specific discretions will advantage those older than 55 (age 50 for protected members). To mitigate this, all discretion will be applied in a fair, consistent and transparent manner. 8.3 Any proposed amendment to the Council’s application of pension discretions will be Equality Impact Assessed under the related policy, process or provision. 9. Consultation 9.1 Consultation was undertaken with Strathclyde Pension Fund Office (SPFO) in relation to the additional statement of regulations, Chief Officers Resources and Regulatory and Regeneration. The Trade Unions have been provided with a copy of Appendix 1 for information on 28th October 2025 and were made aware of this review at the Trade Union Convenors meeting on 21st October 2025. 10. Environmental Sustainability 10.1 There are no environmental sustainability implications. 11. Strategic Assessment 11.1 This proposal aligns with the Council’s strategic objective of maintaining transparency around financial discipline in decision-making to increase value for money assurance for Council Taxpayers delivering efficient and cost- effective services, contributing to its priority of ‘Our Council – Inclusive and Adaptable’. Victoria Rogers Chief Officer People & Technology Date: 16 October 2025 Person to contact: Lisa MacGregor People & Change
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Church St, Dumbarton. Tel: 07949 800801 Email: lisa.macgregor@west-dunbarton.gov.uk Appendix: 1. Appendix 1 West Dunbartonshire Council Policy Statement Local Government Pension Scheme (Scotland) Regulations 2018 Background Papers: None Wards Affected: None