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Pensions: Joint DB/DC trustee agenda update - for August 2022 meetings

Welcome to our monthly update on current legal issues, 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. We also have a separate DC-only briefing

Dashboards developments (new)

The pace of work towards the introduction of pensions dashboards is increasing: the government has published a response to its consultation on the dashboards regulations (read more), a summary of dashboards policies (read more) and a further consultation (read more). The Pensions Dashboards Programme is consulting on the standards schemes will need to meet: read more.

The Pensions Regulator (TPR) has published initial guidance on complying with dashboards requirements: read more.

ACTION: Ensure your scheme is taking steps to meet the requirements in the regulations and standards, taking TPR’s guidance into account.

TPR transfers guidance (new)

TPR has updated its transfers guidance in relation to transfers being prevented where they trigger a flag because they involve overseas investments or small-scale incentives (in particular, ‘refer-a-friend’ rewards). Among other things, the guidance encourages trustees to consider whether non-statutory transfers should be considered where a statutory transfer is prevented. Read more.

ACTION: Consider whether your transfer processes should be updated to reflect this guidance.

TCFD reporting requirements and SIP/implementation statement guidance

Schemes in scope for TCFD reporting requirements (including £1bn+ schemes in the second wave of the rollout) will have to include ‘Paris alignment’ reporting from 1 October 2022 for scheme years ending after that date. The government has produced updated statutory guidance to reflect these new requirements.

The government has also updated its guidance on reporting in statements of investment principles (SIPs) and implementation statements, to provide greater clarity on stewardship. Compliance with statutory elements of the guidance is required for scheme years ending on or after 1 October 2022. Read more.

ACTION: Discuss the new requirements and guidance with your investment advisers.

HMRC GMP equalisation guidance (new)

HMRC has published guidance on payment of interest on pension scheme arrears where a pension has been underpaid because it did not account for GMP equalisation. Read more.

ACTION: Consider this guidance as part of any ongoing GMP equalisation project.

TPR guidance: reporting pension scams

TPR has published a guide on reporting pension scams, including when to report, what information to provide and what will happen next. Read more.

ACTION: Make sure your processes for reporting suspicions of scams follow the new guide.

Regulations on investment consultancy (IC) and fiduciary management (FM) (updated)

Regulations on strategic objectives for IC providers and competitive tenders for FM services will come into force on 1 October 2022. They largely replicate the existing requirements, but there are some changes to be aware of: read more.

ACTION: Check whether your IC/FM arrangements are impacted by the new rules.

TPR annual funding statement

TPR’s latest annual funding statement has a focus on current market uncertainties. All DB schemes and sponsors should familiarise themselves with the content, and especially those with an effective valuation date between 22 September 2021 and 21 September 2022 (Tranche 17), or where funding and risk strategies are being reviewed in connection with wider scheme changes. Read more.

ACTION: Review the statement and consider whether any changes are required to your scheme’s funding strategy or processes.

Watch this space

  • The government has consulted on changes to the notifiable events regime. There is currently no revised date for the delayed regulations, but the industry expectation is that this may be October 2022: read more.
  • TPR has consulted on its proposed single code of practice: watch our webinar on the proposals and read TPR’s interim response. On timing, TPR’s recent corporate plan states only that the code will be published ‘during 2022’.
  • Consultation on new DB funding regulations is expected shortly. TPR has announced that, subject to the timing of the regulations consultation, it is planning to launch its second consultation on the new DB funding code in autumn 2022, with the new code becoming operational from September 2023: read more.
  • A revised code on transfers, and other materials from the Pension Scams Industry Group, are expected imminently.
  • TPR will be launching a joint consultation with the Financial Conduct Authority (FCA) and DWP on a Value for Money Framework by the end of the year.

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