Key issues for your trustee agenda

January 2025

We recommend prioritising these issues on your new year agenda:

With connection dates now heading fast towards us, ensure your dashboards preparation is on track. As TPR warns, trustees are ultimately accountable for dashboard compliance, and must not simply assume that other parties have everything in hand. Schemes should have robust governance in place to track progress, manage risks, and ensure data quality.
Are you up to date with recent publications? TPR released refreshed dashboards guidance, with some significant updates and clarified expectations, in mid-December; the PDP issued updates to its data standards, reporting standards and code of connection in November; and additional PASA guidance was shared.
TPR reminds schemes that they need to be alert to developments as they happen, and to liaise regularly with relevant third parties. TPR’s recent ‘hot topic’ publication covers how trustees should be working with advisers, providers and administrators to meet their duties. Further TPR articles, and design standards, are expected early in 2025.

TPR recently declared that its future approach to regulation will focus upon improved data quality, raising standards of trusteeship, and scheme investments – all of which are inextricably linked with good governance.
Schemes may be starting work towards their first Own Risk Assessments (or ‘ORA’) under TPR’s ‘General Code’ in 2025, where relevant. All schemes should have analysed their current governance standards against TPR’s expectations. Our Pensions Governance Hub, that allows schemes to assess, comply and maintain their compliance with the Code, can help you with this.

Announcements made at the October 2024 Budget and November Mansion House Speech are likely to see schemes undertaking work in 2025.
The industry looks forward to clarity on aspects of the Inheritance Tax on Pensions consultation (to which TLT is responding). Speak to us for actions trustees and employers should be taking in light of the announcement, to ensure your scheme, administrators and members are all prepared.
Increases to employer NICs at the Budget may also mean that some schemes are contemplating changes to their contribution rates and salary sacrifice offerings. If this is relevant to you, take advice, and remember to undertake consultation with members as required.
DC schemes large to small may be considering consolidation as the push towards value increases in 2025. Speak to us to see how our expertise could help you.

TPR’s DB funding Code, statement of strategy guidance and template, its regulatory approach and ‘twin-track’ model guidance, and revised employer covenant guidance, have all now been published, completing the picture for the new DB funding regime. TPR’s new digital service for submitting funding documents is expected to launch in the spring.
The detailed covenant guidance expands on the Code and sets out TPR’s expectations. Familiarise yourself with it, and review your existing covenant analysis against the new requirements, checking that your approach is focussed appropriately for your scheme. While the new guidance has an increased focus on proportionality, schemes should note that TPR expects all DB trustees to read relevant sections in full, and to apply it in contexts beyond valuations – for example, in corporate activity scenarios.
Having identified how the new requirements apply to your scheme, and considered what your funding and investment strategy will look like, take legal, actuarial and covenant advice where relevant. Work out what further information you will need, and start dialogue with your sponsors.