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Pensions: DC trustee agenda update - February 2023

Welcome to our monthly update on current legal issues for trustees of DC pension schemes, designed to help you stay up to date with key developments between trustee meetings and to support the legal update item on your next trustee agenda.  

Market volatility: regulators’ guidance UPDATED

The Pensions Regulator (TPR) has published guidance on actions it expects trustees to take regarding the impact of current economic conditions on DC benefits. The guidance focuses on improving member communications and support, strengthening governance and oversight, and ensuring investment strategies support stronger saver outcomes (read more).

A number of regulators, including TPR, have also recently released statements in relation to liability-driven investments (LDI) (read more). The statements set out expectations in relation to levels of resilience to future market movements. TPR’s statement – following on from its October guidance on managing investment and liquidity risk (read more) – comments on pension scheme governance arrangements, and sets out steps it expects schemes to implement.

ACTION: Read the statements and consider any scheme-specific implications and actions.

DC transfers guidance UPDATED

TPR has updated its guidance on dealing with transfer requests, with changes aimed at helping schemes ensure that members receive the right advice to satisfy legislative requirements where an ‘amber flag’ is raised in relation to a transfer (read more).

The Pensions Administration Standards Association (PASA) has published good practice guidance on DC transfer processes. It includes example member communications, checklists and a transfer template (read more). While the guidance is voluntary, PASA anticipates that the Pensions Ombudsman will use it as a reference point when reviewing complaints.

ACTION: Check your processes against the guidance.

Dashboards developments

Regulations setting out the requirements for dashboards and schemes interacting with them, including the staging deadlines for connection to the dashboards ecosystem, have been approved (read more). The Pensions Dashboards Programme has published: a revised suite of standards (read more); a new consultation on design standards (read more); and an at-a-glance guide to the staging timetable (read more). In addition, the government has finalised guidance for schemes considering applying for deferral of their connection deadline (read more) and TPR has published a draft dashboards compliance and enforcement policy for consultation (read more).

ACTION: Ensure your scheme is taking steps to meet its dashboards requirements.

Watch this space

  • The government has consulted on changes to the notifiable events regime. There is currently no revised date for the delayed regulations (read more).
  • TPR has consulted on its proposed single code of practice: watch our webinar on the proposals and read TPR’s interim response. Publication of the revised version of the code is expected soon.
  • Regulations removing certain performance-based fees from the DC default fund charge cap and making changes intended to increase investment in illiquid assets are expected early in 2023 (read more).
  • A revised code on transfers, and other materials from the Pension Scams Industry Group, are also awaited.
  • TPR will be launching a joint consultation with the Financial Conduct Authority (FCA) and DWP on a Value for Money Framework in 2023.
  • The Chancellor announced in the Autumn Statement that the results of a review of the current timetable to increase the state pension age will be published in early 2023.

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