WEST MIDLANDS PENSION FUND

Regulatory changes (including McCloud)

McCloud remedy 2021 to 2023 data collection

Background

The McCloud judgment arose from a legal challenge against the 2014 reforms to public sector pension schemes which were found to have unlawfully discriminated against younger members. To rectify this discrimination, the ‘McCloud remedy’ was introduced, requiring schemes to adjust members' benefits. 

In December 2022 we completed the first data collection phase, collecting hours and service breaks for members between 1 April 2014 and 31 March 2021. 

Data submission

We launched phase two of our McCloud data collection covering the period from 1 April 2021 to 31 July 2023 during our mid-year review on 1 July 2025. 

The submission window for the next McCloud data collection will run from 1 July 2025 to 30 September 2025. 

Submissions must be made through the Admin Referral workflow in Employer Self-Service (ESS) using the same file layout as the 2014 to 2021 data collection.

Importantly, this time you will only need to submit data for members who have changed their working hours or had service breaks within the period (1 April 2021 to 31 July 2023). 

Our guidance about the file completion and submission process is available below. 

Data processing

We can only apply high-quality data to members’ records. Where data is not submitted or is not accurate, we will apply assumptions in line with the Scheme Advisory Board (SAB) guidance.

If you have any queries, please contact us at WMPFEmployerLiaison2@wolverhampton.gov.uk

Data requirements
Period Requirements Channel
From 1 August 2023 onwards All member changes submitted in real-time Via standard interface using the ESS process
1 April 2021 to 31 July 2023 Member hours (changes only) and service breaks Via Admin Referral workflow using the SAB file layout
1 April 2014 to 31 March 2021 [SUBMISSION WINDOW CLOSED] Member hours (all members) and service breaks Via submission process in Employer Hub (old portal)
Submission guidance
McCloud 2021-2023 Sample File Service Breaks
Download
McCloud 2021-2023 Sample File Hour Changes
Download
McCloud 2021-2023 File Template Hours Changes
Download
2025 McCloud Data Collection Template Notes
Download
McCloud 2021-2023 File Template Service Breaks
Download
McCloud Admin Referral Guide
Download
McCloud data collection 1 April 2014 to 31 March 2021

The submission window for phase 1 of the McCloud data collection closed in November 2022.