Pensions law trustee update - Q2 2023

Priorities for trustees this quarter are to:

  • Be aware of the changes introduced by the Spring Budget 2023 and understand the impact these will have on their scheme and membership;
  • Consider their position regarding LDI in light of likely regulation in this area later this year;
  • Consider the Pension Scams Industry Group Guide for practitioners on combating pension scams when considering transfers out, and in particular statutory transfers out. The guide provides useful steps that trustees and administrators should consider to help comply with the statutory transfer out requirements;
  • Be aware that the deadline for connection to a pension dashboard will be delayed. Trustees should, however, make the most of this extra time to ensure they are connection ready by the revied date; and
  • Be aware of the Pension Regulator's (Regulator) expectations for steps trustees should take if their sponsor is in difficulty.

In addition, trustees should be aware that:

  • Guidance has been published by PASA setting out key steps trustees should consider taking with regards to their data before approaching the insurance market for a buy-in or buy-out of benefits; and
  • There are numerous consultations underway that could introduce additional obligations on trustees of schemes with defined contribution benefits. This is likely to include requirements to:
    • Disclose their asset allocation in their chair's statement in respect of the assets in their default funds for the first scheme year which ends after 1 October 2023; and
    • State their policy in relation to illiquid assts in their default SIP the first time it is revised after 1 October 2023 and at the latest 1 October 2024.
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