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The implementation statement: how to prepare for it

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Bowden Neil
Neil Bowden

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Higgins Jane
Jane Higgins

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Cork Andy
Andy Cork

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Shaw Jason
Jason Shaw

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Kerslake Jessica
Jessica Kerslake

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09 March 2020

Trustee disclosure requirements on investment governance issues, stewardship and engagement continue to evolve rapidly; the new disclosure requirements that apply from 1 October 2020 will affect some pension scheme trustees within just a few months, so it’s time to start preparing.

Trustees of most schemes with 100 or more members must include an implementation statement when they publish the scheme’s annual report in the 12-month period starting on 1 October 2020. The government's intention is that trustees should set out in their statement of investment principles (SIP) what they intend to do, and then report back on whether they have done it. Trustees must also publish the implementation statement online and tell members about its availability.

Just as all SIPs are scheme-specific, all implementation statements will differ. Our latest guide includes a list of questions to consider as trustees start to draft their first statement.