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Pensions: what's new this week December 2, 2024

Welcome to your weekly update from the A&O Shearman pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions.

DB Funding code: Fast Track submission tests and conditions published

Under the new DB Funding Code, trustees of a DB scheme may choose to submit their valuation to the Pensions Regulator (TPR) using either the ‘Fast Track’ or ‘Bespoke’ submission routes. If a scheme meets these regulatory parameters then, in broad terms, TPR will require less information in the scheme’s Statement of Strategy and will apply a lighter touch in terms of scrutiny and engagement.

TPR has now published the Fast Track submission tests and conditions that must be satisfied for schemes that select this route. A Fast Track submission must include a confirmation from the scheme actuary that the valuation meets Fast Track parameters and that the various conditions are met. TPR highlights that the actuary is not being asked to confirm whether the Fast Track route is appropriate for the scheme or whether the legislation and principles in the Code are being complied with; just that, as a factual matter, the tests and conditions are met.

Read the Fast Track submissions test and conditions.

DB and hybrid scheme return questions updated

TPR has published details of the questions to be included in the 2025 scheme return for defined benefit and hybrid pension schemes. New or updated questions will cover:

  • Measurement of data quality – previously schemes have been asked about measurement of common or scheme-specific membership data over the last three years. The question will now need to be answered in relation to the last 12 months.
  • Membership data – schemes will be asked for the numbers of members in different benefit categories at the last scheme year end date on or before March 31, 2024, for the calculation of the general levy for the year from April 1, 2025.
  • Investment consultancy providers – schemes will be asked when they last reviewed the performance of, and the strategic objectives set for, their investment consultancy provider. If no review has taken place, trustees must explain why.

Schemes will receive scheme return notices from December 2024 onwards; the deadline for submission of the return on Exchange is March 31, 2025.

Read the scheme return information.