Pension Scheme Administration: Revised Pensions Regulator Guidance

The Pensions Regulator (TPR) has published revised guidance on the administration of pension schemes. Targeted at trustees and scheme managers, the guidance provides practical steps to ensure high-quality administration that meets TPR's expectations set out in the "Administration" section of the General Code. It is of general application, whether the scheme's administration is provided by a third-party administrator or by an in-house administration team.

What does the guidance cover?

In addition to refreshing TPR's previous guidance on administration, the guidance contains several new elements, including:

• The importance of schemes having a written administration policy/strategy, robust documented arrangements with their administrators, and a clear administration manual;
• The need for schemes to have robust arrangements to enable the effective oversight of administration, including appropriate reporting, and to broaden performance measurement beyond time-based measures for a true reflection of the quality and accuracy of the administration service; and
• Guidance on IT system governance, including assurance on system adequacy, change control processes, technological benefits with proper oversight, regular backups, and cyber resilience.

The guidance also sets out clarifications on key administration activities and considerations, including:

• Member communication;
• Contributions and transfers;
• Data management; and
• Disaster recovery and business continuity planning.

What should schemes be doing?

TPR expects schemes to use the guidance as a practical framework to strengthen administration, improve oversight, and build effective partnerships with their administrators. Trustees and scheme managers should review the guidance and consider whether any changes should be made to their scheme's administration arrangements.

How can Mayer Brown help?

We can help trustees and scheme managers by:

• Advising on their legal and regulatory obligations in relation to administration and on administration governance processes.
• Advising on their current contractual arrangements with their administrator.
• Reviewing and updating administration contracts and administration policies/strategies to ensure they provide clear allocation of responsibilities, appropriate governance and monitoring arrangements, and suitable trustee protections.
• Providing training/knowledge sessions on administration and contractual arrangements.
• Advising on specific administration issues, such as business continuity arrangements, record-keeping, administration policies/strategies, data protection, and cyber security.

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.