Yet another busy year ahead in the pensions world!
To help you navigate successfully through 2022, here are 20-20 Trustees’ key dates for your trustee diary.
TPR code of practice
In early spring, look out for TPR’s single code of practice which is due to go before Parliament. Trustees will be well-aware of this code, which combines 10 of TPR’s existing 15 codes of practice into an updated and online format. Given the scale of its content, many trustees are already engaging with it – if not, you need to start now.
Assuming it gets through parliament (and it should), occupational pension scheme trustees will be expected to establish and operate an effective system of governance (ESOG) and an “own risk assessment” (ORA). The first ORA will need to be documented within one year of the code coming into force and annually thereafter.
Our advice is to have a clear breakdown of all tasks you’ll need to do and plan ahead. 20-20 Trustees is already working with schemes to complete governance checklists, identify any gaps and strategise for the future. If you feel unsure or overwhelmed, get in touch now.
DB Funding Code delayed
The second consultation into TPR’s new defined benefit funding code will be delayed until late Summer 2022, with TPR saying it is “vital we take the time to get it right.” TPR has emphasised that the principles established in the first consultation, which set out a “fast-track” and a “bespoke” route, remain the right ones. It’s expected that the code will go live in 2023.
Stronger Nudge to pensions guidance
The Stronger Nudge to pensions regulations are expected to come into force on 1 June 2022. The regulations will require occupational pension schemes to present guidance as a routine part of accessing or transferring pensions savings. Pension schemes will need to offer to book a Pension Wise appointment for individuals unless they wish to opt out of receiving guidance. The new measures will require trustees and administrators to amend their processes to ensure they are fully compliant, and this is something you should be doing now.
Climate Change Guidance for £1bn+ schemes
October 2022 sees the climate risk reporting and governance regimes introduced. From 1 October schemes with assets of £1 billion or more, will have to comply with the governance and disclosure requirements set out by the Task Force on Climate-related Financial Disclosures (TCFD). As a cause fully supported by 20-20 Trustees, we can supplement TPR’s guidance in this area with bespoke advice and support to trustees to help you determine whether or not you have met the requirements of the regulations and indeed go beyond them.
On 1 October a fourth metric for climate risk reviewing will be introduced which is based on reporting how investments align with the Paris Climate Agreement.
Keep an eye on our news and LinkedIn pages as we will providing plenty of useful updates and advice on all things green.
Get ready for buy-out
We can expect to see trustees continue to plan for future buy-outs as more schemes work through their journey planning. 20-20 Trustees has realised several buy-out transactions including for the pension schemes sponsored by Toshiba and 600 Group PLC.
We have guided numerous schemes through buy-outs on both a Trustee board and sole Trustee basis, and under both models, we have worked hard to secure members’ benefits, eliminate unnecessarily high advisory costs and execute the transaction within critical timescales.
The legal intricacies of the buy-out are complex which is why many peers turn to our expertise at 20-20 Trustees.
Make a note of these deadlines:
- 31 March – Sending scheme returns and contingent asset certificates to TPR
- 31 March – Sending asset backed contribution certificates and special category applications to the PPF
- 31 March – The closure of legacy public sector pension schemes to further accrual, followed by opening of new public sector pension schemes to accrual on 1 April
- 31 March – Covid-19 easement on scheme administrative process ends
Other deadlines for your diary include:
- 29 April – deadline for sending exempt transfer application to the PPF
- 30 June – deadline for certifying full block transfer with TPR
These are just some of the main trends and milestones for all of us in the pensions sector over the coming 12 months – and we haven’t even mentioned the pensions dashboard, CDC schemes, DC charges or even the continued impact of Covid.
2022 is going to be another interesting year for trustees and our 20-20 Trustees’ experts will be on hand to guide you all the way.
If you wish to seek further advice and clarification on any of the above, then 20-20 Trustees has a range of experts who can help. Please feel free to get in touch by contacting us today.