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Winding up: avoiding delays

This guidance provides suggestions of good practice to help trustees and others meet the two-year time frame in relation to winding up occupational pension schemes.

It concentrates on common, complex areas that can delay the wind-up, rather than looking at each activity involved in the process.

The guidance is also relevant to trustees of live schemes as it is good practice to ensure a scheme is well administered whilst ongoing, regardless of whether winding up is being considered.

Our Trustee toolkit also provides information on the wind-up process.

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Key points

  • The regulator expects that schemes already winding up should complete at least the key activities as soon as possible and within two years, and schemes commencing winding up following publication of this guidance should complete at least the key activities within two years.
  • The guidance is aimed at those with some experience or knowledge of the wind-up process – trustees, administrators, insurers and professional advisers.
  • We advise those with limited knowledge or experience to complete the winding-up modules on the Trustee toolkit first.
  •  To avoid unreasonable delays we encourage trustees to adopt a pragmatic and proportionate approach, where appropriate, whilst working in line with the provisions of the trust deed and rules, their fiduciary duties and any legislative requirements.
  • We encourage parties to have a project plan in place in order to ensure that the two-year time frame can be achieved.
  • We are aware that the reconciliation of contracted out liabilities is a time-consuming task and advise that surrendering the contracting out certificate and beginning the reconciliation process are among the first activities undertaken in the wind-up process.