Continuity option 2 (resolving triggering event)

CDC code in force: 31 July 2026

1. Continuity option 2¹ is for the triggering event to be resolved. We are more likely to be satisfied where the trustees’ continuity strategy shows that they have considered how this continuity option could be applied under each applicable trigger event. This requirement is in conjunction with the general requirement to address how members’ interests will be protected during a triggering event period.
2. We are more likely to be satisfied that the continuity strategy is adequate if it addresses the issues set out below.

Identifying options for resolving a triggering event

3. Trustees should consider whether:
   1. there are any known potential remedies available for resolving a certain triggering event.
   2. they will seek legal and professional advice and how those costs can be met

Communications

4. Trustees should consider:
   1. if, how and when they will communicate with beneficiaries and employers in considering options for resolving a triggering event and how communication costs will be met
   2. how they will comply with the requirement to notify TPR that the triggering event is resolved
   3. timescales for resolving the event and meeting costs
5. The strategy should include²:
   1. clear timescales for resolving the event using any of the mitigation options identified
   2. any critical milestones
   3. how long the trustees can fund an attempt to resolve an event before switching to continuity option 1 (discharge and wind-up) or continuity option 3 (conversion to closed scheme)
   4. a contingency plan to cover the costs of resolving an event if resolution takes longer than expected
   5. a summary of the assumptions behind any estimated figures

Legal references

¹ Section 37 of the Pension Schemes Act 2021

² Regulation 15 of the 2022 Regulations and Regulation 38 of the 2025 Regulations

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