Pensions law trustee update - Q2 2024
Priorities for trustees over the summer are to:
- Understand the implications of the changes made to the funding regime for DB schemes.
- DB pension scheme trustees are required at the time of their first actuarial valuation with an effective date on or after 22 September 2024 to put in place a "funding and investment strategy" and to comply with the new legislative regime as well as the requirements of Pensions Regulator's new Funding Code; and
- Ensure they are aware of the deadline of 31 October 2026 for schemes to be connected to the pensions dashboards ecosystem and the (optional) staged timetable for connection, and to understand what steps they and their scheme administrators will need to take prior to connection.
In addition, trustees should be aware that:
- Labour reportedly no longer intends to reintroduce the lifetime allowance if elected next month;
- We still await, however, further amending Regulations to correct errors in the new lump sum allowances legislation and expect that we will not get these before September 2024.
- In the meantime, HMRC has suggested that in some situations members hold off taking or transferring certain benefits; and
- The Pensions Ombudsman has published a very interesting determination (CAS-55100-G3W9) on the recovery of overpayments by trustees, and the circumstances in which a valid defence to recovery may be available.
