The Pensions Brief: April 2024

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The Pensions Regulator (TPR) has published its latest review of TCFD reports. The review covered 30 reports for scheme years ending between 1 October 2022...
UK Employment and HR
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Issues affecting all schemes

Climate change – TCFD reports

The Pensions Regulator (TPR) has published its latest review of TCFD reports. The review covered 30 reports for scheme years ending between 1 October 2022 and 30 September 2023, representing around 10% of the total reports for that period. Key findings included:

  • It was helpful to include scheme information near the beginning of reports to put the rest of the report in context.
  • When referring to specific investment mandates, it was helpful to explain their size relative to the total scheme assets.
  • The quality of reports could be improved by including specifics on policies in place, steps taken to manage risks and information received from advisers, rather than generic wording.
  • Reusing parts of previous reports is a sensible way of producing the report efficiently. However, if trustees take this approach, they should include a summary of developments and activities during the reporting year.
  • The quality of reports did not necessarily correlate with their length. Some better reports were more concise and efficient in how they addressed disclosure requirements.
  • Some reports had excellent plain English summaries aimed at members. This allowed the remainder of the report to be written with a more informed/technical reader in mind, potentially aiding brevity.
  • Where trustees have used the reporting process to identify additional work that needs to be carried out, they should set an action plan for this, monitor progress and update on progress in their next report.

The review also provides specific feedback on each section of the reports, setting out good practice observed, issues observed and ways to improve future reports. For more information, please see our legal update.


Trustees of schemes that are subject to the requirement to produce a TCFD report should review TPR's findings and consider what needs to be factored into their next TCFD report.

Pensions dashboards – data standards

The Pensions Dashboards Programme (PDP) has published an updated version of the data standards for pensions dashboards. The data standards set out the data formatting requirements that schemes must follow when returning pensions data and are designed to help schemes understand how to provide the data. The standards remain subject to ministerial approval.

The PDP has also published FAQs on connecting to the dashboards ecosystem and the recently published statutory guidance setting out the staged connection timetable. The FAQs cover:

  • Ways to connect.
  • What the "connect by" date is and why it is important for schemes to connect by that date.
  • Whether the PDP will p
  • How schemes can defer connection to a later date.


Trustees and administrators should review the updated standards and factor them into their dashboards preparations.

New lump sum regime – further guidance

HMRC has published further guidance on a number of areas relating to the abolition of the lifetime allowance (LTA) and the new lump sum regime, including benefits which are paid on or after 6 April 2024, entitlement to which arose prior to that date. HMRC has also published a consolidated version of the FAQs that it has published in relation to the abolition of the LTA and the new lump sum regime.


No action required, but trustees and administrators may find the guidance and FAQs helpful.

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Originally Published 8 May 2024

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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.

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