Pensions law trustee update - Q2 2022

Priorities for trustees this quarter are to:

• understand the impact of the war in Ukraine on their pension scheme investments and their sponsor covenant. The Pensions Regulator (TPR) has provided a list of considerations for trustees to take into account;
• understand their proposed onboarding date to the pensions dashboard service and consider the steps that will need to be taken to ensure their scheme is 'dashboard ready'. This may require some substantial data cleansing work to ensure that scheme data is accurate, up to date and meets the expected standards of the draft dashboard regime.

In addition, trustees should be aware of:

• the prohibition on the imposition of flat fees by trustees and managers of occupational pension schemes used for automatic enrolment, where the value of a member's rights under a default arrangement is below £100;
• the delay of the extension of the notifiable events regime, which was expected to come into force on 6 April 2022; and - potential future amendments to the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021 to ensure that low-risk overseas investments are not caught by the new advice requirements.