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An ambitious project for The Pensions Regulator

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The Pensions Regulator has announced its plans to combine its existing 15 codes of practice into a single code.  The new code is expected to be shorter, quicker to find, use and update, and comes as part of its new ‘clearer, quicker and tougher’ initiative.  A formal consultation is to follow later this year.  This is an ambitious project and one that is very unlikely to be completed quickly.

This follows the EU’s IORP II Directive coming into force, along with the associated UK regulations, which place a new requirement on certain occupational pension schemes to establish an effective system of governance – building on the previous requirement for trustees to maintain adequate internal controls.  Trustees are now expected to have an effective system of governance in place that is proportionate to the size, nature, scale and complexity of their scheme. The new single code will reflect the Regulator’s expectations in this area. 

It is expected that the code will be developed in phases, with early focus on the codes of practice most affected by the new requirements.  Once the new code is in force, trustees will have 12 months to demonstrate their compliance. Delivering on this announcement will not be easy. Combining all 15 existing codes into a sensible single one is a tough ask, but the Regulator deserves the support of the pensions industry as it tries to do so.

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