Welcome to your weekly update from the A&OShearman Pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions.
TPR Climate change report
The Pensions Regulator (TPR) has published its second Climate Adaptation Report, discussing progress in relation to climate change considerations. The report summarises current occupational pension scheme requirements and TPR's initiatives in this area. It draws on the results of its recent DB and DC scheme surveys to illustrate schemes' levels of engagement. TPR notes that larger schemes typically outperform smaller ones and suggests that smaller schemes unable to address climate risk should exit the market.
The report highlights areas in which TPR believes schemes need to do more work, including: increased trustee awareness of transition plans and their benefits (the government has committed to mandating transition plans for pension schemes and TPR notes that this will be a particular focus moving forward); increased and less generic focus on physical risks; greater attention to the potential for stranded assets; more recognition of nature and biodiversity risks; more detailed consideration of triggers and impacts of market re-pricing; reflection of 'double materiality' i.e. that both (a) climate-related impacts on a company and (b) the impacts of a company on the climate, can be material; improved scenario analysis; and consideration of systemic risks. TPR recognises several potential barriers to progress and suggests that some of those barriers can be used to enable change.
Read the report and accompanying press release.
PASA: Guidance on data readiness for buy-ins and buy-outs
The Pensions Administration Standards Association (PASA) has published new guidance on data readiness for buy-ins and buy-outs. This builds on, and should be read in conjunction with, previous guidance published in 2023. The 2023 guidance covers the key data items that should be held for all members; actions trustees can take in advance of a buy-in/out to demonstrate good governance; and some 'quick wins'. The new guidance sets out actions to be included in a data-cleanse plan and practical tips for carrying this out. It also suggests things to consider when identifying and preparing essential data, including tables of key principal data items that schemes are expected to hold electronically and notes on dealing with that data. PASA suggests that the principles set out in the guidance can also be used by schemes not intending to buy-in/out.
ECCTA: Voluntary identity verification
The Economic Crime and Corporate Transparency Act 2023 (ECCTA) set out a range of measures intended to prevent the use of corporate entities for criminal purposes, which are gradually being brought into force (see link below for a fuller summary of the changes). The measures include new identity verification requirements for directors, persons with significant control (PSCs), relevant officers of a registrable relevant legal entity and members of limited liability partnerships. By autumn 2025, Companies House is expected to make identity verification a compulsory part of incorporating a new company and for appointing new directors and PSCs; there will be a 12-month transition phase for existing directors and PSCs. Companies House has now launched a service allowing individuals to verify their identity voluntarily if they wish, with accompanying guidance.
Identities can be verified directly with Companies House or through an Authorised Corporate Service Provider (ACSP). Companies House has also published guidance for ACSPs on how to verify information.
Read the Companies House guidance on verifying identity directly and guidance for ACSPs.
Read our 'ECCTA: where are we and what's next' briefing.
Next edition of What's new this week?
Our next edition of 'What's New This Week?' will be published on April 28, 2025. We hope you have a lovely break.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
