Preparing for a triggering event

CDC code in force: 31 July 2026

Assessing the risk of a triggering event

1. We are more likely to be satisfied about a continuity strategy where the trustees of a single-employer CDC scheme or the scheme proprietor of a multi-employer CDC scheme have assessed and outlined:
   1. which triggering events are more likely to occur in relation to the scheme
   2. which continuity options are available to the trustees in each case
   3. where more than one continuity option is available, how the trustees will decide which one to follow
   4. any condition in the scheme’s deed and rules that would automatically cause a triggering event and pursuit of one of the continuity options
   5. the risk and potential impact on members following a triggering event

Planning initial response to a triggering event

2. We are more likely to be satisfied where the continuity strategy sets out:
   1. how the trustees will initially respond to a triggering event, including how and when they will first assess risks and impacts
   2. the process for making decisions, showing where they can be delegated in the absence of a key decision-maker
   3. the principles for identifying and managing conflicts of interest that may arise following a triggering event
   4. any role, function, or named person to be involved in producing the implementation strategy

Continuing to operate the scheme during a triggering event period

3. We will only consider a continuity strategy where the trustees have set out the matters 
   required by regulations¹, including how they would:
   1. manage triggering event notifications in line with requirements and statutory timeframes
   2. decide which continuity option to pursue, if there is more than one viable continuity option available
   3. continue to run the scheme while fulfilling duties arising from a triggering event
   4. meet the costs of operating the scheme during the triggering event
   5. communicate with members, employers and us
   6. maintain members’ records
   7. comply with any legal requirements
   8. meet actuarial requirements
   9. manage investments and make investment decisions
   10. deal with any contributions due from employers and members
   11. ensure administrative services would continue, including a summary of any arrangement or provision under contract for service that would continue during a triggering event and pursuit of any one of the continuity options
   12. ensure continuity of services, including that any arrangements for appointing key roles and advisers will continue to operate in the event of any roles being left vacant
   13. ensure that the continuity strategy deals with a triggering event that has occurred
4. Trustees should explain the assumptions behind any estimates provided².

Choosing a continuity option

5. The continuity strategy must provide the framework and key steps on how the trustees will decide to pursue (or follow, where required) one of the following continuity options:
   1. Continuity option 1 (discharge liabilities and wind up).
   2. Continuity option 2 (resolve triggering event).
   3. Continuity option 3 (close the scheme to new contributions or new members).
6. We are more likely to be satisfied where the trustees can show they have considered each continuity option available to them for each triggering event, in conjunction with the general requirement to address how the trustees will protect members’ interests during a triggering event period.

Meeting the costs of dealing with a triggering event

7. The activities identified in the continuity strategy must be appropriately costed and assumptions clearly stated alongside estimate figures provided. Trustees must explain how they will meet the costs, noting the prohibition on increasing or adding new administration charges during a triggering event period³.

Statement of administration charges

8. The continuity strategy must set out:
   1. all levels of charges for each charge structure, for the current scheme year and on an annualised basis
   2. whether or not any additional, third party or other types of administration charges apply
   3. the reasons for imposing any of the charges above
9. We are more likely to be satisfied where the charge levels provided are consistent with the financial information and assumptions provided for the financial sustainability criterion.

Legal references

¹ Regulation 15 of the 2022 Regulations

² Regulation 15(2) of the 2022 Regulations and regulation 38(2) of the 2025 Regulations

³ Section 45 of the Pension Schemes Act 2021

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