We'd recommend prioritising these issues on your spring agenda:

  • Prepare to give DC and AVC members a ‘Stronger Nudge’
  • Get ready for the Regulator’s forthcoming single code
  • Progress your GMP projects – equalisation and conversion

And an update on notifiable events.


Get ready for the Regulator's single code

  • The Pension Regulator’s new “single code of practice” is expected to be laid before Parliament this summer. While we expect some changes to the final version of the code, now is the time to act.

  • To be compliant with the new code, pension schemes must have an “effective system of governance” in place.

ACTION: Download our handy single code preparation guide and “own risk assessment” fact pack to help you think about the steps you need to take before the code comes into force in the autumn.


Prepare to give DC members a Stronger Nudge

  • From 1 June 2022, schemes must ‘Nudge’ members or survivors who are seeking to transfer, or start receiving, flexible (DC) benefits to take ‘appropriate guidance’.

  • TPR updated its related guidance on directing members to Pension Wise (including sample member declarations).

ACTION: ensure your scheme and administrators are ready. In particular, check your scheme communications, and record keeping procedures. See our Stronger Nudge fact pack for further key information.


Progress your GMP projects

  • Schemes should be continuing to work on their GMP equalisation projects. With further guidance out in recent weeks from HMRC and PASA, there’s plenty to consider.
  • An Act to simplify GMP conversion achieved Royal Assent at the end of April, making the law less ambiguous, and more user-friendly as a potential equalisation solution. We now await underlying regulations and guidance to give further detail.

ACTION: Speak to your usual TLT Pensions contact about how we can help.

Still awaited:

The industry had expected new and updated notifiable events to come into force on 6 April 2022. However, we still await the response to the DWP’s consultation, and any specifics on timing.

Watch out for further updates – and prepare to factor action into forthcoming corporate plans.


Date published

09 May 2022

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