Pensions Round-Up APRIL 2021 - DLA Piper
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APRIL 2021 Pensions Round-Up
PENSIONS ROUND-UP Contents Introduction...............................................................................................3 The Pensions Regulator ..........................................................................4 Legislation and the Pension Protection Fund ..................................7 Other news .................................................................................................9 On the horizon.........................................................................................11 Contact details.........................................................................................12 2
DLAPIPER.COM
Introduction
• Other news: HMRC’s pension
Welcome to the latest edition of DLA Piper’s Pensions
schemes newsletter 129;
Round-Up newsletter in which we provide an an updated version of the Pension
Scams Industry Group’s code
overview of developments in pensions legislation
on combating pension scams;
and regulatory guidance. and the launch of an inquiry
about stewardship by the Work
and Pensions Committee.
In this edition we look at key developments from
• On the horizon: a timeline
April 2021 including the following.
of some of the key future
developments in pensions to
• The Pensions Regulator: of schemes providing money
help employers and trustees
the Regulator’s climate change purchase benefits to prepare
plan ahead.
strategy; and a blog post in a chair’s annual statement.
relation to the new criminal
• Pension Protection Fund: If you would like further information
offences of avoidance of employer
the PPF’s response to its about any of the issues raised in
debt and conduct risking accrued
consultation on changes to the this edition of Pensions Round-Up,
scheme benefits.
actuarial assumptions for section please get in touch with Cathryn
• Legislation: a report on a post 143 and section 179 valuations; Everest or your usual DLA Piper
implementation review of the and an update on the Fraud pensions contact. Contact details
legislation requiring trustees Compensation Fund levy. are at the end of this newsletter.
3PENSIONS ROUND-UP
The Pensions Regulator
Climate change (including climate change) that PLANNED ACTIONS
strategy they consider financially material. Sections of the strategy on
On 7 April the Regulator published It also notes the requirements regulatory approach, influencing
its Climate change strategy which for publication of the SIP and the debate and taking part in the
sets out its strategic response to implementation statements. transition include information about
climate change and how it thinks the Regulator’s planned products
that it can help trustees meet the AIMS AND OBJECTIVES and outputs and which objective
challenges from climate change. The strategy sets out the following each relates to. These planned
three aims for the Regulator, as actions include the following.
STRATEGIC CONTEXT well as objectives in relation to each
The Regulator states that climate of them. • The Regulator will publish
change is systemically significant to guidance that clarifies what it
pensions, to its regulatory regime • The Regulator will create will be looking for from schemes
and to its statutory objectives. better outcomes in later life as they assess, manage and
It states, for example, that climate for workplace savers by driving prepare to report in line with
change is directly relevant to its trustee action on the risks and the climate change measures
objective of protecting member opportunities from climate in the regulations to be made
benefits; if trustees fail to consider change. The objectives in relation under the Pension Schemes Act
risks and opportunities from climate to this aim include that the 2021. When the regulations are
change, or fail to exercise effective Regulator wants to see schemes reviewed in 2023, the Regulator
stewardship, they face the risk that publish their SIP, implementation will work with the DWP to share
investment performance will suffer. statement and, where applicable, best practice TCFD reports.
disclose their TCFD report.
• The new single code of practice
The section on strategic context It states that where schemes do
will include modules on climate
also refers to the proposed new not do this, and it is appropriate
change and stewardship.
regulations to be made under the to do so, the Regulator will take
provisions of the Pension Schemes enforcement action, which it may • The Regulator will further support
Act 2021 on climate change risk, publicise. The Regulator states the development of trustees’
which will impose requirements that these disclosures represent knowledge and understanding by
on trustees of certain schemes compliance with the basics on updating the content on climate
in relation to governance and climate change. change in the Trustee Toolkit.
disclosure. (Further information
• The Regulator will seek to • The Regulator will examine
on these proposals is on pages 6
influence debates around scheme reports on scenario
to 7 of the January 2021 edition of
pensions and climate change. analysis in more detail by carrying
Pensions Round-Up.) The Regulator
The objectives in relation to this out a thematic review on scheme
states that, while the mandatory
aim include that the Regulator resilience to climate-related
disclosure of climate risks in
will: use communications to scenarios. It will publish its
line with the TCFD (Task Force
help nudge those who run findings and use them to inform
on Climate-related Financial
pension schemes to comply with any revisions to its guidance.
Disclosures) recommendations
legislation and take account of
initially applies to larger schemes • The Regulator notes the
its guidance; and work across
and all master trust and collective requirement for trustees to
the financial sector towards
DC schemes, all schemes already report on stewardship and
consistent behaviours and high
have duties in relation to climate engagement activities through
quality information for trustees
change. It refers, for example, to an implementation statement.
on climate risk.
the requirement for the Statement It states that it will review a
of Investment Principles (SIP) • The Regulator will, as a business, selection of implementation
to include the trustees’ policies take part in the transition to statements and publish
in relation to stewardship and in net zero. its findings.
relation to ESG considerations
4DLAPIPER.COM
• To help identify instances of On 19 April the Regulator published providers and administrators can
non-compliance with disclosure a blog post by its Executive Director sign up to the pledge through the
obligations, the Regulator will of Regulatory Policy, Analysis and Regulator’s website to show their
reflect requirements in the new Advice entitled Time for some commitment to combat pension
regulations by adding questions perspective on our criminal offences scams. Pledgers will use the
to the scheme return requesting powers. The Executive Director notes Regulator’s resources and online
website addresses for the SIP, that several industry commentators education tools to understand
implementation statement and have speculated on the what they can do to protect savers,
TCFD report. consequences of these new powers. with the six pledge steps including
He also states that he has seen regularly warning members
• The Regulator will publish on
“debate about where the lines are about pension scams, and taking
its website an index of the web
drawn” and that concerns have been appropriate due diligence measures
addresses of schemes’ SIPs.
expressed that the powers could and documenting pension transfer
• In autumn 2021, the Regulator potentially catch normal behaviour. procedures. When the six pledge
will publish its Climate Adaptation However, he goes on to state that: steps are met, pledgers can self-
Report, which will outline “The Minister has made it quite certify to demonstrate to their
its findings on how those clear the intent is not to achieve a members and to the pensions
running pension schemes are fundamental change in commercial industry that they are following
responding to and managing norms or accepted standards of the pledge principles. On 8 April
the risks and opportunities corporate behaviour in the UK”. the Regulator added the recording
from climate change. The blog post states that many of its pledge to combat pension
scenarios that are presented to the scams webinar to its website, which
EVALUATION Regulator focus on a particular act, is designed to support the pensions
The strategy states that the but the power requires intent, an industry to make the pledge.
Regulator will set milestones as act and the absence of a reasonable
points at which to check against its excuse, and that, together, “those DB schemes – asset
objectives. It states that it will see if represent a high bar”. information
it achieved what it set out to do, as On 29 April the Regulator and the
part of the bigger picture of moving The blog post states that, when Pension Protection Fund (PPF)
towards a landscape of resilient the new powers come into force, published a joint consultation
pension schemes that protect they should not worry those who are on proposed changes to the
savings from climate risk. doing the right thing and properly asset class information that the
thinking through the actions and Regulator collects annually from
Regulator’s decisions they take, but that they DB schemes via the scheme return.
new powers should “cause a deal of anxiety The consultation states that, given
The Pension Schemes Act 2021 for those who intentionally want changes to the pensions investment
contains provisions introducing to avoid liabilities or put pension landscape and with a focus on being
new powers for the Regulator, savings at risk”. “clearer, quicker and tougher”, the
including two new criminal offences Regulator will be seeking to improve
which are expected to come into The blog post also includes the scheme information it holds.
force in the autumn: the offence of that the Regulator: will not The Regulator wants to be able
avoidance of employer debt and the overstretch the intent and better to understand the investment
offence of conduct risking accrued purpose behind the powers; will landscape to provide more guidance
scheme benefits. As reported always take an appropriate and and scrutinise trends and changes
in our Pensions Alert dated proportionate approach; and will in the market. It therefore requires
18 March 2021, on 11 March the not be targeting acts pre-dating more granular investment data to
Regulator published a consultation the offences coming into force. be submitted. The consultation also
on a draft policy setting out notes that the PPF has an interest in
its proposed approach to the Pension scams a better assessment of investment
investigation and prosecution of In November 2020 the Regulator risk for the purposes of charging a
these new offences. launched its ‘pledge to combat risk-reflective levy.
pension scams’ campaign. Trustees,
5PENSIONS ROUND-UP
The proposals are largely derived the bespoke stress calculation; Automatic enrolment
from the more granular set of and (6) schemes will be able to and DC contributions
asset categories used in the “trade up” tiers and voluntarily guidance
bespoke stress calculation for the provide more information if
Since 1 November 2020, the level
PPF levy. The Regulator and the they wish.
of the Coronavirus Job Retention
PPF want to take a proportionate
Scheme (CJRS) grant has been 80%
approach to the data they collect, The consultation explains that
of employees’ wages for hours not
reflecting that smaller schemes the key area of change proposed
worked, capped at GBP2,500 per
may have more limited resources is around bond investment
month. The cap is proportional to
and simpler investment strategies. categorisation. For Tier 1, the
the hours not worked.
They therefore propose a Regulator and the PPF would like
tiered approach. to refine the bond categories to
In the Budget 2021, which took
reflect those that small schemes
place on 3 March, it was announced
In summary, it is proposed that: most commonly invest in. For Tier 2
that: the CJRS will be extended until
(1) the boundary between Tier 1 and Tier 3, they would like to collect
the end of September 2021; and
and Tier 2 schemes will be set at more information on the maturity,
employees will continue to receive
GBP20 million (based on section quality and currency of the schemes’
80% of their wages for hours not
179 liabilities at the most recent bond investments.
worked, but the government will
valuation), although the consultation
introduce an employer contribution
also seeks views on whether a The consultation closes on
towards the cost of unworked hours
higher initial threshold is needed 10 June. In terms of next steps,
of 10% in July, 20% in August and
while provision of more granular the consultation includes that:
20% in September. As has been the
information becomes routine; (1) the Regulator plans to
case since August 2020, employers
(2) the boundary between Tier 2 and update its IT systems to enable
cannot claim for employer National
Tier 3 will be set at GBP1.5 billion; the collection of new asset
Insurance Contributions or
(3) for Tier 1 schemes, information class data in time to support
pension contributions.
will be requested at the current the introduction of the new DB
level of detail, with only minor funding code; (2) the Regulator will
On 9 April, the Regulator updated
refinements, including the ensure schemes have sufficient
Automatic enrolment and DC pension
introduction of a diversified growth notice before implementation;
contributions: COVID-19 guidance
fund (DGF) category; (4) Tier 2 and (3) the PPF would then expect
for employers to reflect the changes
schemes will be asked to provide to make associated changes to the
to the CJRS and wider government
more granular information, based PPF levy rules.
support announced in March 2021.
on the asset categories used in
The Regulator also updated its
the PPF’s existing bespoke stress
technical guidance on salary
calculation; (5) schemes in Tier 3
sacrifice arrangements and the CJRS
will also continue to carry out
to reflect the changes to the CJRS.
6DLAPIPER.COM
Legislation and the Pension
Protection Fund
Chair’s statement CONCLUSIONS the scheme’s regulatory activity.
The report states that, whilst all It notes that further work will
BACKGROUND
the relevant governance provisions be required between the DWP,
In 2015 a statutory requirement
were looked at as part of the review, the Regulator and industry
was introduced for trustees of
“the strong feeling around the representatives to ensure
schemes which provide money
purpose and effect of the Chair’s common agreement on content.
purchase benefits (subject to
statement was a very important
limited exceptions, including for
issue”. The conclusions of the review The DWP also states that it will
DB schemes where the only money
include the following. consider whether the chair’s
purchase benefits are AVCs) to
statement should be used by
prepare an annual statement,
• The government and the trustees to disclose whether
signed by the chair, regarding
Regulator should consider they have requested costs and
scheme governance. The trustees
the audience and role of the charges information using the
are required to make certain parts
chair’s statement in relation to Cost Transparency Initiative
of the chair’s statement (relating
scheme governance and member (CTI) templates, as part of its
to costs and charges and the
communication. The report commitment (from the recent Review
statement of investment principles
states that: (1) it is clear that of the Default Fund Charge Cap and
for the default arrangement)
the current format of the chair’s Standardised Cost Disclosure) to drive
publicly available free of charge on a
statement is not working as a up use of the templates.
website. Regulations made in 2016
document intended for multiple
require the Secretary of State, from
audiences; that is, for the trustees PENALTIES FOR
time to time to carry out a review
to demonstrate good governance, NON-COMPLIANCE
of certain legislative provisions
while also serving as a provider of Where trustees have indicated
relating to governance (including
information to scheme members; that they have failed to prepare
the provision requiring a chair’s
and (2) work is required between a compliant statement or the
statement) and publish a report in
the DWP and the Regulator “to Regulator is of the opinion
relation to that review. In line with
revisit this issue and to provide that they have failed to do so,
the deadline of 6 April 2021 for the
clarity to the pensions industry the legislation provides that the
first report, a Post Implementation
to remove collective confusion Regulator must impose a penalty
Review report has been published.
and ambiguity”. of at least GBP500, but no more
than GBP2,000. The report
THE REVIEW • The information to be contained
includes that: (1) the role of the
The report explains that: (1) the in the chair’s statement should be
Regulator in ensuring compliance
review took the form of sending revisited, with the report stating
and the imposition of fines was
a letter to pension providers/ that this will be determined
raised by most of the responders;
representative bodies and once the intended audience
and (2) the clear message, in
scheme members’ representative of the statement has been
particular from pension providers,
organisations with a short list clarified. The report states that
was to advocate strongly for the
of questions framed around an area to explore is whether the
Regulator to have the power to use
the legal requirements of the information should be in a single
discretion about the imposition of
review; (2) this was followed up document which members have
such fines. The report notes that
with targeted discussions with sight of or whether there is a
the legislative requirement for
responders; and (3) discussions need to divide the requirements
mandatory penalties was not within
were also conducted with the into different documents, for
the scope of the review. However,
Pensions Regulator to inform example, one that is member-
the report’s conclusions include
the review. facing and one which records
7PENSIONS ROUND-UP
that, whilst not within scope of PPF valuation the following.
the review, consideration should be assumptions
given to this legislative requirement On 4 February the PPF published • In November 2020, a court
and whether there should be an a consultation on proposals to ruling clarified that occupational
amendment to allow the Regulator change the actuarial assumptions pension schemes set up as
to use discretion. It notes that, for section 143 valuations (PPF part of a scam were eligible
working proactively with scheme assessment valuations) and section to claim on the FCF. (In relation
providers on shortfalls in the 179 valuations (PPF levy valuations). to the background to this case, a
content of the chair’s statement The consultation explained that November 2020 update from the
would align with how the Regulator legislation requires the PPF to PPF included that: (1) a number
works more generally with the keep the assumptions in line with of claims had been made to the
pensions industry. estimated pricing in the bulk annuity FCF to compensate members of
market, and the PPF is proposing occupational pension schemes
Reporting to HMRC changes to bring the assumptions that were themselves part of
The Pension (Non-Taxable into line with current market a scam; (2) pension savers
Payments Following Death) (Real pricing. The proposed changes were incentivised to transfer
Time Information) Regulations relate to mortality assumptions, their pension from a genuine
2021 were made on 26 April 2021 discount rates and the calculation occupational pension scheme
and will come into force on 6 April of expenses. into these scam schemes; and
2022. The regulations provide for (3) the court confirmed that these
the mandatory reporting, to HMRC On 28 April the PPF published its types of claims are eligible for FCF
through the Real Time Information response to the consultation. The PPF compensation and clarified the
(RTI) system, of certain non-taxable states that the response to the core principles that apply.)
payments made to beneficiaries proposed changes was generally
• The Board has a number of claims
after the death of a member (for positive and there was acceptance
from such schemes, with a total
example, the balance of a five year that bulk annuity prices had altered
value of over GBP40 million, and
guarantee and certain lump sum sufficiently as to merit a change to
expects to receive more claims
death benefits). the assumptions. The PPF states that
from schemes which have been
it has decided to proceed with the
confirmed as eligible to apply
HMRC’s Tax Information and Impact majority of the proposed assumptions,
for compensation.
Note about the regulations includes but with an amendment to the
that: (1) this change will require mortality assumptions for section 143 • The PPF’s 2019/20 Annual Report
pension payers to report certain valuations. The changes came into and Accounts confirmed that the
non-taxable payments to HMRC effect from 1 May 2021 for FCF had assets of GBP21.5 million.
using RTI; and (2) this will provide both section 143 and
• Given the value of the claims that
HMRC with complete information section 179 valuations.
the Board has already received
about an individual’s pension
and its expectation that further
payments and help ensure that Fraud
claims will be made, it needs to
they pay the correct amount of tax. Compensation Fund
raise a levy of 75p per member
The Explanatory Memorandum On 1 April the PPF published an
(30p for master trusts) in 2021/22,
notes that HMRC’s guidance does update reporting that the Fraud
which is the maximum allowed
not currently reflect the reporting Compensation Fund (FCF) levy
under current regulations.
of non-taxable payments and it will for 2021/22 has been confirmed.
be updated to coincide with the By way of background, the FCF: • The levy will be collected on the
regulations taking effect. We will pays compensation to occupational Board’s behalf by the Pensions
report further once the guidance pension schemes which have lost Regulator, together with other
is updated. out financially due to dishonesty; is fees and levies that all pension
funded by a levy on eligible pension schemes must pay.
schemes; and is administered by the
Board of the PPF.
The April update includes
8DLAPIPER.COM
Other news
HMRC pension schemes • The Framework Document The Technical Guide states that
newsletter details the context, structure and the regulations under the Pension
On 30 April HMRC published principles of the code. Schemes Act 2021 are expected
pension schemes newsletter 129 to be in place by October 2021,
• The Practitioner Guide details
which includes reminders that: and a further update to the
the robust and proportionate due
(1) a Pension Scheme Return is only code will be issued to reflect the
diligence steps to be undertaken
required for schemes in respect new regulations.
by trustees and administrators
of which a notice to file a return is
of pension schemes assessing
received from HMRC; (2) ahead of Work and
the pension scam risk of a
migration of pension schemes to Pensions Committee
requested transfer.
the Managing Pension Schemes On 29 April the Work and
service, administrators will need • The Resource Pack contains Pensions Committee announced
to enrol on the service under their materials which practitioners the launch of an inquiry on
existing scheme administrator can use to undertake the pension stewardship and COP26.
ID; and (3) for schemes operating due diligence detailed in the The Committee notes that,
relief at source, the deadline for Practitioner Guide, including following the DWP’s January 2021
submitting the 2020/21 annual example scripts, letter and consultation, the government is
return of information is 5 July 2021. discharge form wording. due to bring in regulations for
The newsletter also reports that, pension schemes on managing
• The Technical Guide details
as part of its annual updates, climate risk ahead of the UK hosting
the rationale behind the
HMRC has amended the annual the COP26 climate conference in
guide, including legislative and
allowance calculator to include the November. The Committee states
regulatory requirements.
2021/22 tax year. that its inquiry is examining the
• The Summary of Changes details government’s approach to pension
Combating the changes made to the code scheme stewardship, how it
pension scams since the previous version (2.1) compares to approaches taken
On 1 April the Pension Scams was issued in June 2019. internationally, and how funds can
Industry Group (PSIG) published be supported to make
an updated version of its code Recent developments that are climate-conscious
on Combating Pension Scams reflected in the updated code investment decisions.
(version 2.2) which takes effect from include: the Pensions Regulator’s
1 April 2021 and is available for use pledge to combat pension scams The Committee’s call for evidence,
in any transfer request processed campaign; regulatory developments which closes on 18 June 2021,
on or after that date, even if the from the Financial Conduct raises questions including:
request for a transfer was received Authority; Pensions Ombudsman (1) how pension schemes should
before that date. The voluntary code determinations; and the regulations contribute to setting COP26 targets
represents good industry practice which are being developed under and helping to achieve the targets
on due diligence. The updated provisions of the Pension Schemes once agreed; (2) whether there
version reflects recent regulatory Act 2021 to restrict the statutory are suitable financial products to
and legislative changes as well right to transfer. Other changes enable pension funds to make
as the evolving nature of pension include that additional questions climate-conscious investments,
scams. Changes have also been have been included within the and how such investments should
made to improve usability, with the Questions To Ask Members section, be facilitated and supported; and
code now divided into five chapters. and case studies have been revised. (3) whether pension schemes have
suitable information to assess
climate risk, or whether there need
to be international reforms to
financial reporting.
9PENSIONS ROUND-UP
Treasury Committee • The Committee states that the Teachers’ Pension
On 22 April the Treasury Committee Treasury should report regularly Scheme
published a report entitled Net Zero on the proportion of pension On 7 April the Department for
and the Future of Green Finance holders in DC schemes who Education published a consultation
as part of its decarbonisation and remain in the default fund, on proposed changes to the
green finance inquiry. In relation to and the extent to which those Teachers’ Pension Scheme
pensions, the report’s conclusions default funds are aligned with regulations. The consultation
and recommendations include a path to net zero. relates to proposals to amend the
the following. scheme regulations: (1) to provide
• The Committee states that
female members in an opposite
consumers who hold DB
• The report states that there is sex marriage or civil partnership
pensions have no choice as to
a high level of inertia amongst with the same survivor pension
how their assets are allocated
consumers around DC pension rights as female members in a same
and are therefore reliant on
fund choice, with most remaining sex marriage or civil partnership;
the scheme trustees. It states
in the ‘default’ fund. It states that and (2) to allow for the phased
that, in the phased approach to
the Treasury “has been robust withdrawal of independent
implementing the regulations
in its view that default funds schools. The consultation also
to be made under the provisions
should not be required to move proposes some miscellaneous
of the Pension Schemes Act 2021
to more green alternatives, minor amendments including to
in relation to climate change, the
but at the same time maintains make minor drafting corrections.
Pensions Regulator will need to
that consumers should not The consultation closes on 1 June
consider how to reach smaller
have to switch out of the default and the government response
pension schemes. The Committee
fund to invest sustainably”. is expected to be published in
states that, in responding to its
The Committee states that the summer 2021.
report, the government should
government should “resolve
set out how these smaller
this apparent contradiction”.
funds will be encouraged to
integrate climate governance and
reporting requirements.
10DLAPIPER.COM
On the horizon
DATE DEVELOPMENT
Unknown In February 2020 the Regulator published the response to its July 2019 consultation on the future of trusteeship
and governance. Action points that the response identifies include that the Regulator will review and update its
code of practice on Trustee Knowledge and Understanding, review the Trustee Toolkit and establish and lead an
industry working group to find ways of supporting schemes to take steps to improve trustee diversity.
Following the publication of its October 2020 Statement of Policy Intent entitled Stronger Nudge to Pensions
Guidance, the DWP is expected to publish a consultation on draft regulations to implement its proposals.
2021 In April 2019 the DWP published guidance on GMP conversion which notes that the government is considering
changes to this legislation to clarify certain issues. The GMP Equalisation Working Group plans to publish
examples on anti-franking in the second quarter of 2021. The Working Group also plans to publish guidance on
GMP conversion, communications during the implementation stage and past transfers.
2021 Regulations to implement provisions of IORP II in relation to governance came into force in 2019, with the detail of the
new requirements to be set out in a code of practice. On 17 March the Regulator published a consultation on the first
phase of its work to combine its current codes to form a single, shorter code. The consultation closed on 26 May 2021.
2021 Following the government’s March 2019 response to its consultation on Collective DC schemes, a framework for such
schemes is included in the Pension Schemes Act 2021. The DWP plans to consult on regulations in early summer 2021.
Second The Regulator’s second consultation on its DB funding code, which will focus on the draft code itself, is expected
half of 2021 to be published in the second half of 2021.
Autumn The Pension Schemes Act 2021 includes provisions which amend the Regulator’s powers and introduce new
2021 powers. The aim is for the powers to be available to the Regulator by autumn 2021. In relation to the duty to give
notices and statements to the Regulator in respect of certain events, the DWP will consult on the draft regulations
later this year, for commencement as soon as practical thereafter.
Early In August 2017 the government confirmed that it will proceed with proposals to limit the statutory right to
autumn transfer in order to tackle pension scams. Regulation-making powers are included in the Pension Schemes Act
2021 2021. Regulations are expected to be introduced in autumn 2021. The DWP published a consultation on draft
regulations on 14 May 2021.
October The Pension Schemes Act 2021 includes provisions on climate change risk which set out powers to make
2021 regulations imposing requirements on trustees in relation to governance and disclosure. The DWP has published
a consultation on draft regulations and statutory guidance and it is proposed that the regulations will come into
force on 1 October 2021.
October Annual Reports produced on or after 1 October 2020 have to include implementation statements.
2021 The information to be included in these statements depends on whether the scheme is a relevant scheme or a
DB scheme. The first report for DB schemes and certain information for relevant schemes must be published by
1 October 2021.
October In September 2020 the DWP published a consultation on proposals to improve outcomes for DC members which
2021 looks at issues including assessing value for members, consolidation and the charge cap. The consultation closed
on 30 October and it is proposed that the regulations will come into force on 5 October 2021.
2021 Provisions in relation to pensions dashboards are included in the Pension Schemes Act 2021. An indicative
timeline published by the Pensions Dashboards Programme in October 2020 estimates that phase 4 of the
2023
development of pensions dashboards, which will be the phase in which schemes will begin to be compelled by law
to connect to the dashboards ecosystem, will run from 2023. The DWP aims to consult on proposed regulations for
the pensions dashboard later in 2021.
2022 On 17 May 2021 the DWP published a consultation on draft regulations introducing simpler annual benefit statements
for DC schemes used for automatic enrolment. It is proposed that the regulations will come into force on 6 April 2022.
11PENSIONS ROUND-UP
Contact details
Cathryn Everest Ben Miller Andrew McIlhinney
Senior Professional Support Head of Pensions Partner, Leeds
Lawyer, London +44 (0)151 237 4749 +44 (0)113 369 2141
+44 (0)20 7153 7116 ben.miller@dlapiper.com andrew.mcilhinney@dlapiper.com
cathryn.everest@dlapiper.com
Tamara Calvert Matthew Swynnerton
Megan Sumpster Partner, London Partner, London
Professional +44 (0)20 7796 6702 +44 (0)20 7796 6143
Support Lawyer, London tamara.calvert@dlapiper.com matthew.swynnerton@dlapiper.com
+44 (0)20 7153 7973
megan.sumpster@dlapiper.com Joel Eytle Amrit Mclean
Partner, London Head of Pensions De-risking
+44 (0)20 7796 6673 +44 (0)20 7796 6613
joel.eytle@dlapiper.com amrit.mclean@dlapiper.com
12DLA Piper is a global law firm operating through various separate and distinct legal entities. Further details of these entities can be found at dlapiper.com. This publication is intended as a general overview and discussion of the subjects dealt with, and does not create a lawyer-client relationship. It is not intended to be, and should not be used as, a substitute for taking legal advice in any specific situation. DLA Piper will accept no responsibility for any actions taken or not taken on the basis of this publication. This may qualify as “Lawyer Advertising” requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome. Copyright © 2021 DLA Piper. All rights reserved. | MAY21 | A09960-2
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