This guide is for the people who run trust-based occupational pension schemes — trustees, scheme managers and the providers operating master trusts. The regime is The Pensions Regulator's, not the FCA's, and it applies UK-wide. One boundary to fix first: contract-based pensions — group personal pensions and stakeholder schemes — are insurance products, run by an insurer under its own PRA and FCA authorisation; for those, see insurer authorisation and prudential rules. The one part of this guide that reaches contract-based schemes is the final section: any scheme used for automatic enrolment, trust-based or contract-based, must meet the qualifying-scheme requirements. If you are a third-party administrator acting for trustees rather than running the scheme, your duties are in run a regulated financial services firm.
Register the scheme with The Pensions Regulator
A registrable occupational scheme must be registered with TPR, keep its registrable information up to date, and complete the annual scheme return. Master trusts need TPR authorisation before operating at all.
Meet the funding regime for defined benefit schemes
If the scheme provides defined benefits, the statutory funding objective applies: technical provisions, a funding and investment strategy, recovery plans where there is a deficit, and actuarial valuations on the statutory cycle.
Meet the trustee knowledge and understanding requirements
Trustees must have the knowledge and understanding the law requires — of pensions and trust law and of their own scheme's documents — and keep it current.
Connect to pensions dashboards
Schemes in scope of the Pensions Dashboards Regulations 2022 must connect to the dashboards ecosystem in line with the staged connection timetable — and in any event by the regulatory connection deadline — and be able to find and return members' pension data.
Qualifying-scheme requirements for automatic enrolment
If employers use your scheme to meet their automatic enrolment duties, the scheme itself must be a qualifying scheme: minimum contribution levels, and — for defined contribution qualifying schemes — the default fund charge cap. The employer's own enrolment duties are the employer's; your side is keeping the scheme qualifying.
Next steps
Make sure the shared duties in run a compliant insurance or pension business are in place, then confirm everything with the insurance and pension compliance checklist.
Legal basis
Primary legislation and key regulations