An IGC chair preparing for the first reporting cycle under CP26/1 has a manageable but non-trivial agenda. Some of it — producing the regulatory rating — is now a defined exercise that the provider's data infrastructure will support. Some of it — producing the Annual Statement narrative that goes beyond the rating — is genuinely new analytical work and needs to be commissioned in time. The questions worth working through before the cycle begins are operationally focused.
Does the rating answer the IGC's question to its members?
The rating answers the question the regulator has set: is the arrangement delivering acceptable value on the defined regulatory dimensions? The IGC's question to its members is connected but different: is the arrangement delivering acceptable outcomes for you, the member, in your particular circumstances? Where these two questions have the same answer for every member, the rating is sufficient and the Annual Statement narrative can rest on it. Where they don't — which is most arrangements with heterogeneous memberships — the IGC needs analytical material the rating doesn't supply.
What does an outcome-focused Annual Statement look like?
An Annual Statement that goes beyond the rating tells members what they're actually on track to receive in retirement, given their current trajectory and the arrangement's behaviour. It articulates the distribution of outcomes across the membership, not just the central tendency. It identifies where the arrangement is and isn't serving members at different points in that distribution. It places the IGC's view explicitly: here is what we think is acceptable, here is what we think needs to be improved, here is what we are doing about it.
This is more substantive content than a rating-driven Annual Statement and requires analytical apparatus the regulatory rating doesn't supply. Member-outcome distributions, welfare-relevant characterisation of the membership, and lifetime modelling of how the current arrangement behaves are the analytical building blocks.
What about the data?
Most providers' member-data infrastructures hold what's needed to produce the rating. Producing analytical material that goes beyond the rating typically draws on the same data — member contributions, fund holdings, retirement-age expectations, contribution rates — reorganised analytically. The data acquisition tends not to be the gating step. The analytical apparatus is. IGCs working with providers whose data is in good order can move faster on the analytical commission than IGCs working with providers whose data needs work first.
What about the timing?
The first reporting cycle starts later than the date by which the analytical layer needs to be specified. Specifying the analytical layer late produces an Annual Statement narrative that defaults to the rating because the analytical material isn't ready in time. IGCs that have started the conversation in 2026 or 2027 have the time to specify properly, calibrate the analytical layer to the membership, and have the material ready before the first cycle. IGCs starting in 2028 do not.
Three questions to take to the next IGC meeting
The first question is simply whether the IGC's Annual Statement is going to rest on the regulatory rating alone, or whether the IGC wants analytical material that goes beyond it. The second is, if it's the latter, what specifically the IGC wants the Annual Statement narrative to address — member outcomes, distributional features, the IGC's own substantive view on remediation. The third is who is going to do the analytical work, with what data, and in what timeline.
These three questions answered together produce a Year 1 Annual Statement that the IGC can stand behind. Answered separately they produce a Year 1 Annual Statement that defaults to the rating because the analytical apparatus didn't make it in time.
Last updated May 2026.