FOI reference - FOI-265
Date - 4 June 2024
Request
A list of pensions schemes who are known to invest into private markets (private debt, private equity, infra, real estate).
If a list is not available, please can you tell me:
- How many pension schemes allocate to private markets generally?
- How many schemes allocate to private debt?
Can you provide the above for both DC and DB schemes, please.
Response
I confirm that we hold the information you have requested. However, some of the information you have requested is exempt from disclosure.
Section 44(1)(a) – restricted information under s82 PA04
In relation to your request for a list of pension schemes who are known to invest into private markets, we have been given strong powers to demand documents and other information from trustees, employers and others, those powers are also balanced by restrictions on how we disclose the information provided to us. The type of information you have requested would be ‘restricted information’. Restricted information is defined at section 82(4) of the Pensions Act 2004 (PA04) as:
‘…information obtained by the Regulator in the exercise of its functions which relates to the business or other affairs of any person’.
Under section 82(5) of the PA04 it is a criminal offence to disclose such information except as permitted under that Act.
Whilst the FoIA is based on the presumption of releasing information, section 44(1)(a) of the FoIA provides an absolute exemption to the requirement to disclose any information if its disclosure is prohibited by or under any enactment. In this case, section 82 of the PA04 prohibits disclosure and we are unable to disclose the requested information. This exemption is absolute and does not require a public interest assessment be undertaken.
However, we can disclose the information requested in the second part of your request. Based on 2024 DB Scheme Return submissions, there are:
- circa 1,290 unique PSRs that have an allocation to 'Private Debt'
- circa 1,600 unique PSRs that have an allocation to 'Unquoted or private equities'
The way that asset splits are recorded is dependent on the size of the scheme, so not all schemes provide their asset splits in the same way. In addition, it should be noted that the above is based on the raw asset splits provided in the 2024 Scheme Returns and we do not verify whether every allocation is accurately recorded in line with our guidance as we do not have the information to do so.