Issues affecting all schemes

Pensions dashboards – staging timetable delay

The government has announced that the staging timetable for connection to the pensions dashboards ecosystem will be delayed. The government has said it will legislate to amend the staging timetable as soon as possible, but it has not indicated when the revised timetable might begin. No other changes are being made to the requirements to which schemes will be subject under the dashboards legislation. For more information, please see our legal update.

Action

Trustees and administrators should continue with their dashboards preparation while awaiting further announcements from the government on the revised staging timetable.

ESG and climate change – reporting compliance

The Pensions Regulator has launched a campaign to ensure that trustees are meeting their ESG and climate change reporting obligations. As part of the campaign, the Regulator will launch a regulatory initiative in the spring to check whether schemes with 100+ members have published their statement of investment principles (SIP) and implementation statement on a publicly available website. A review of a crosssection of SIPs and implementation statements will follow in the summer. The outcome of this review will be shared with the industry to highlight good practice. The Regulator will also issue a statement on "Taskforce for ClimateRelated Financial Disclosures" reports this spring. For more information, please see our legal update.

Action

Trustees should ensure that they have published their scheme's SIP and most recent implementation statement on a website that is accessible free of charge by the general public.

Transfers – reporting suspicious activity

The Financial Conduct Authority (FCA) has published a webpage asking schemes and trustees to report any serious concerns that they have identified about a transfer including:

  • Individuals who provide unauthorised advice on transfers.
  • Increases in the volume of transfers advised by the same adviser.
  • If a member has requested a transfer following a cold call or unsolicited contact.
  • If the member has been offered an incentive to make a transfer.
  • If the receiving scheme has high risk or unregulated investments.
  • If the receiving scheme's charges are unclear or high.
  • If the receiving scheme's investment structure is unclear, complex or unorthodox.
  • Potential scam activity.

The page sets out how reports can be made and, for the first two items above, a list of helpful things to consider when making a report.

Action

Trustees and administrators should ensure that they report transfers to the FCA where relevant.

Automatic enrolment – extension of regime

The private member's bill extending the automatic enrolment regime has been withdrawn. The bill would have:

  • Extended the regime to all jobholders aged 18+
  • Removed the lower qualifying earnings limit.

A new private member's bill has been laid before Parliament which would give the government the power to make regulations:

  • Reducing the age at which jobholders become eligible for automatic enrolment.
  • Reducing or removing the lower qualifying earnings limit.

This new bill has the government's support and is therefore likely to be enacted.

Action

Employers and trustees of schemes that are being used for automatic enrolment should keep the new bill's progress through Parliament under review.

Social factors – industry taskforce

Following the government's July 2022 response to its call for evidence on the consideration of social factors by trustees, a Taskforce on Social Factors has been launched. Including representatives from across the industry, the Taskforce's key objectives are to:

  • Identify reliable data sources and other resources which trustees can use to identify, assess and manage financially material social risks and opportunities.
  • Monitor and report on developments relating to the International Sustainability Standards Board and other international standards.
  • Develop thinking around how trustees can identify, assess and manage the financial risks posed by modern slavery and supply chain issues.

Action

No action required.

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