TPR General Code of Practice – 2024

TPR has unveiled its General Code of Practice, set to take effect on March 27, 2024. This comprehensive code consolidates 10 existing codes into one document, presenting the regulator’s expectations regarding the governance of both Defined Benefit (DB) and Defined Contribution (DC) occupational pension schemes. The code introduces new modules addressing areas such as climate change, cyber controls, and pension scams.

Trustees of schemes with 100 or more members must conduct an Own Risk Assessment (ORA) to evaluate the scheme’s governance. The deadline for the first ORA has been extended, providing schemes with at least two years to complete it.

Trustee Actions:

1. Evaluate Governance Structure: Compare the scheme’s governance structure with the expectations outlined in the final Code.
2. Review Policies: Understand existing policies, review dates, and identify potential gaps.
3. Assess Scheme Against Modules: Evaluate the scheme against modules related to effective governance and internal controls.
4. Prepare for ORA (for schemes with 100 or more members): Begin planning for the first ORA, considering frequency, scope, key personnel, documentation, and budgets.
5. Implement Remuneration Policy: Ensure the implementation of a compliant remuneration policy.

Despite the representation that Atkin Pensions, and others made to TPR, few concessions are made for smaller schemes, with no provided templates or example documents.  Small schemes, with more than 100 members will have to carry out an ORA and it appears that the biggest changes to the original proposals have been made to the timescale and fashion in which Trustees must carry out an ORA. 

TPR expects a balanced and proportionate approach to compliance, acknowledging that not all trustees may be fully compliant by the enforcement date.  While full compliance may not be immediate, trustees are expected to actively work towards compliance. Governance failures may face scrutiny if the new standards are not actively implemented. 

For further details and the complete Code, visit The Pensions Regulator’s website.