Puzzle in the dark

The Pensions Regulator releases update on single code of practice

Stuart Henderson, Director, Pension Funds
04/09/2020
Puzzle in the dark
The EU pensions Directive (IORP II) was enacted into UK law on 13 January 2019 and will be included in a Code of Practice to be issued by the Pensions Regulator.

There are a significant number of changes including:

  • more information to be provided to members annually
  • clarity on Trustee remuneration policies
  • the consideration of ESG factors when making investment choices
  • simplifying cross-border transfers. 

Perhaps the most significant change is the emphasis on the need to establish a system of internal controls that are proportionate to the size and complexity of the arrangements.

The regulations refer to a number of areas such as:

  • the need to internally evaluate the adequacy and effectiveness of the system of governance
  • >to consider the effectiveness of internal controls
  • to conduct formal risk management assessments at least every three years
  • to be subject to regular internal reviews.

When can we expect to see the code of practice?

The Pensions Regulator issued a statement in July 2019 that, as part of the review of their code of practices in relation to IORP II, they will be combining the content of their 15 current codes of practice to form a single, shorter code.

The early focus will be on internal controls, the defined contribution code, public service schemes and master trusts as this will set out the features of effective governance that will apply to all types of pension schemes. The Regulator stated that Trustees will need to demonstrate that they have an effective system of governance within 12 months of publication of the updated code.

It was originally planned to be issued for formal consultation over the year 2019-20, however the Regulator has updated the timing of this to later 2020 or early 2021.

How Crowe can help

Crowe are already helping their clients to prepare their schemes prepared for when the expected changes come into play. Please contact Judith Hetherington, Stuart Henderson or your usual contact at Crowe.

Contact us

Judith Hetherington
Judith Hetherington
Partner, Pensions Funds Group
London & Midlands