The Value for Money delay is an opportunity to establish agility through product-led teams

Open your banking app on a Tuesday morning and you can transfer £500 to a friend before your coffee gets cold. Try to contribute £500 to your pension in the same way and, in many cases, you’d get there faster by making a phone call. Upcoming regulation is turning this experience gap into a threat.

Under Consumer Duty, UK pension providers already have to evidence fair value. The regulator’s new Value for Money (VfM) framework will soon make that obligation public, transparent, and directly comparable. Providers will publish standardised metrics across cost, investment performance and service quality, receiving a red, amber or green (RAG) rating that employers and savers can use to compare schemes. Poor ratings will bring mandatory improvement plans, monetary sanctions and, in the worst case scenarios, non-compliant schemes will be closed to new business and their assets transferred to better-performing competitors.

However, firms were recently given breathing room. On 13th July, the DWP and FCA published joint consultation CP26/25, delaying and shrinking the initial data capture period, in which data must be submitted to the regulators for moderation. What was originally a 12-month window starting in January now begins in July and only lasts 6 months – meaning organisations now have an extra 6 months to best prepare. 

Most providers are using this extended runway to re-sequence delivery timelines to be ready for next July – an extremely sensible approach. But scoring well on the framework isn’t just about meeting deadlines. The real strategic opportunity is using the added time to embed product thinking, building organisational adaptability required for future regulatory shifts, customer expectations, and market disruptions.

The current blindspot – projects over products

Across DC master trusts and corporate pension providers, one pattern repeats often enough to be structural rather than coincidental:

This project-based approach is understandable in a risk-averse industry, but it falls short when customer desires evolve rapidly and new regulatory demands are constant. 

Product thinking replaces temporary project delivery with empowered, persistent product teams – cross-functional units of product, design, engineering, data, and compliance specialists who own an end-to-end outcome. These teams focus and pivot based on validated user research rather than static plans set months earlier, giving organisations the agility to respond whenever change occurs.

	Project-based teams	Product-led teams
Inputs	Fixed scope, detailed specifications, single budget allocation (CapEx)	Fluid backlog of opportunities, measured but continuous budget tied to performance metrics (OpEx)
Team	Temporary, shared teams assembled for specific skills, disbanded at completion	Permanent, cross-functional teams aligned to long-term business / domain goals
Definitions of Success	Focus is on outputs – was the right thing created, on time and under budget?	Focus is on outcomes – did what we built help someone achieve something new, or in a quicker, simpler, or more enjoyable way?
Timeframes	Set timeframes (usually months) – products ‘go live’ while teams disband to focus on the next project	Continuous and iterative – the product never ‘ends’ but is living and constantly improved
Risk Management	Focus is on protecting the plan – lots of time is spent upfront planning a risk mitigation strategy. Project manager owns this and tracks this in a RACI matrix (or similar)	Focus is on validating assumptions and understanding threats on desirability, viability, and feasibility of the product. Done up-front, during, and post-release. Product trio shares responsibility for validation and risk management
Adaptability	Rigid – changes are tightly controlled and organised through change requests	Flexible – backlog priorities adapt to new data, user needs, or mandates in real-time

 

How project thinking breaks the product lifecycle

Project thinking doesn’t just stall velocity – it degrades value at each stage of the product lifecycle.

1. Pre-build: The mandate gap

Because regulators and senior leadership dictate much of the pensions roadmap, product teams are rarely handed discretionary backlogs. In essence, project thinking reduces product teams to pure delivery engines. However, while the ‘what’ is often fixed (e.g. publishing VfM metrics or connecting dashboards), the ‘how’ remains open. Product thinking earns its keep by optimising user journeys, sequencing, and presentation – making sure mandated features actually drive saver behaviour rather than landing as noise.

2. In-build: Unquestioned backlogs

Without an outcome-focused mindset, teams can default to wholesale shipping regulatory requirements as monolithic features. Effective product teams interrogate the backlog before a single story enters a sprint, asking ‘What is the smallest increment of this mandate that tests how a saver will actually use it? Where do we have room to choose a better experience, rather than just comply?’

3. Post-build: Measurement as an afterthought

Project delivery ends the moment code deploys, creating critical blind spots. Digital products are routinely shipped without embedded tracking, telemetry, or clean underlying data, leaving providers with no visibility of user behaviour. When measurement and data are treated as secondary bolt-ons rather than foundational elements, providers miss the live insights needed to continuously improve service quality.

Why Product teams win on the VfM Assessment

VfM evaluates three core metrics: cost, investment performance, and service quality.

For many providers, cost structures and investment strategies are hard to alter quickly. Service quality is where providers will win or lose, and it extends far beyond call-centre SLAs – it is the clarity, friction, and efficacy of the digital experience. High service quality also lifts the other two pillars – complex fee schedules and performance numbers become far easier to digest when presented cleanly.

VfM Metric	Traditional response	Product team response
Costs & Charges	Hide fees in complex, static disclosure documents	Design visual and  intuitive dashboards that simplify cost structures and demonstrate value
Investment Performance	Rely solely on quarterly fund performance PDFs	Build interactive tools showing financial performance & projected retirement outcomes
Quality of Services	React to member drop-outs via call centre volume	Track live telemetry to proactively remove journey friction before members experience friction

The cost of a poor rating

Product teams restricted purely to feature execution cannot set direction, validate assumptions and impact, or adjust post-launch, which is a significant liability when service quality dictates a third of a scheme’s VfM score. 

Providers that empower product teams to build engaging experiences and prove better member outcomes will secure green ratings. Those maintaining the status quo risk amber or red indicators. Even during the 2028 test year, before the formal sanctions kick-in, a published red rating is precisely what prompts employers to switch providers. By the time consequences bite in 2029, catching up means fixing structural gaps under live regulatory pressure – a much harder place to start from than where providers stand today.

Using the extended runway to empower your product teams

The pension industry has good reason to be cautious. It’s highly regulated, and deeply meaningful to a lot of people. A wrong step could affect millions of retirement plans. But you don’t need to rewrite your entire corporate operating model. Use the extra six months to establish these core habits within your delivery teams:

1. Expand team remit across the product lifecycle. Shift focus from feature delivery to outcome ownership. Allow teams to run pre-build discovery to optimise mandate delivery, and give them space post-launch to measure saver impact.
2. Separate the mandated from the discretionary, and interrogate accordingly. For regulatory requirements, ask how delivery best serves the saver. For discretionary items, demand clear evidence of user validation. Don’t stop asking either question.
3. Bring Risk and Compliance in early. Utilise service blueprints to map processes cross-functionally. Involving compliance, UX, and technical architecture before build begins might feel slow at first, but prevents costly late-stage rework. 
4. Embed analytics from day one. Tracking, tagging and telemetry belong in the first release, not the retrofit. Define success metrics during discovery so teams can measure actual adoption and gauge impact.
5. Deliver in small, continuous increments. Break large deliverables into smaller, testable releases to validate user assumptions early, avoiding high-risk, “big bang” launches.
6. Empower your individuals and teams to own decisions. Craft experts are exactly that – experts. Giving your specialists the context, clarity, and remit to make product decisions allows them to unlock creative solutions and improves execution speed without increasing risk. Our take on why this matters at an organisational level is set out in It’s the org chart, not tech debt, that’s killing productivity.

Looking ahead

We work with pension providers on the product problem underneath the delivery deadline, not just the deadline itself. Whether you’re building greenfield digital experiences, modernising legacy core platforms, or transitioning from project-based delivery to empowered product teams, we help some of the UK’s largest pension providers build adaptable products, at scale, that perform under regulatory scrutiny to deliver for your members when it matters.