Triggering events and implementation strategy

CDC code in force: 31 July 2026

Triggering events

1. Triggering events are events that may indicate that the scheme cannot continue to operate¹. We must be notified that a triggering event has occurred unless it occurs as a result of a notice that we have issued, as is the case for events 1 to 3 of the triggering event table².
2. We expect the trustees (and in the case of a multi-employer CDC scheme, the scheme proprietor) to have robust procedures for monitoring risks to the scheme, and to be able to identify a triggering event when it occurs. Consequently, where the trustees decide that the scheme is at risk of failure and it is necessary to pursue one of the continuity options, the continuity strategy should in most cases have already identified the risk leading to the failure. In many cases, an associated significant event should have already been reported to us, and the trustees should be in dialogue with us at the time of the triggering event notification.
3. Table 1 sets out the triggering events that we must be notified of. Triggering events apply to all schemes unless otherwise specified.

Table 1: The triggering events TPR must be notified of

Triggering event				Date event occurs
4: Single-employer CDC schemes only		An employer or relevant former employer has an insolvency event		The date of the insolvency event
4A: Multi-employer CDC schemes only		An insolvency event occurs in relation to the scheme proprietor		The date of the insolvency event
4B: Multi-employer CDC schemes only		The scheme proprietor becomes unlikely to continue as a going concern		The earlier of: a. The date on which the scheme proprietor notifies us of the fact b. The date on which the trustees become aware of the fact
5: Single-employer CDC schemes only		An employer or relevant former employer becomes unlikely to continue as a going concern		The date the employer or relevant former employer becomes aware it is unlikely to continue as a going concern
6		A person decides that the scheme should be wound up (where the person making the decision has the power to do so under the scheme rules)		The date of the decision
7		An event occurs which is required or permitted by the scheme rules to result in the scheme winding up		The date on which the event occurs
7A: Multi-employer CDC schemes only		The scheme proprietor decides to end the relationship or arrangement with the scheme		The date of the decision
7B: Multi-employer CDC schemes only		The scheme proprietor ends the relationship or arrangement with the scheme		The earlier of: a) The date on which the scheme proprietor notifies us of the fact b) The date on which the trustees become aware of the fact
8		A person decides that the scheme should become a closed scheme (where the person making the decision has the power to do so under the scheme rules)		The date of the decision
9		An event occurs which is required or permitted by the scheme rules to result in the scheme becoming a closed scheme		The date on which the event occurs
10: Multi-employer CDC schemes only		The trustees decide that the scheme is at risk of failure and need to pursue one of the continuity options		The date of the decision

Notifications to TPR about triggering events

4. If a scheme experiences a triggering event, the trustees, or the employers or former employers must notify us within seven days after the event occurs or, in some cases, after they become aware that it has occurred³. If you are unsure whether a triggering event has occurred, you should seek professional advice.
5. Some triggering events must be reported when a decision has been made⁴. Only binding decisions should be reported, not plans or proposals. A decision can be taken outside a formal meeting, and our expectation is that where clear steps have been taken regarding an event, without a formal minuted decision, a notification will need to be made.
6. Notification duties attached to the triggering events fall into two categories:
   1. Category 1: persons more closely involved with the event must notify us within seven days starting with the date of the event itself.
   2. Category 2: other persons must notify us within seven days starting with the date they first become aware of the event.

Table 2: Notifications attached to the triggering events TPR must be notified of

Triggering event	Category 1		Category 2		Category 2 (when not the decision-maker)
4: An employer or relevant former employer has an insolvency event (single-employer CDC schemes only)	Employer/relevant former employer		Trustees
4A: The scheme proprietor becomes unlikely to continue as a going concern (multi-employer CDC schemes only)	Scheme proprietor		Trustees
4B: The scheme proprietor becomes unlikely to continue as a going concern (multi-employer CDC schemes only)	Scheme proprietor		Trustees
5: An employer or relevant former employer becomes unlikely to continue as a going concern (single-employer CDC schemes only)	Employer/relevant former employer		Trustees
6: A person decides that the scheme should be wound up (where the person making the decision has the power to do so under the scheme rules)	Employer/relevant former employer Trustees [Scheme proprietor] Other decision-makers				Employer/relevant former employer Trustees [Scheme proprietor]
7: An event occurs which is required or permitted by the scheme rules to result in the scheme winding up	Trustees		Employer/relevant former employer		[Scheme proprietor]
7A: The scheme proprietor decides to end the relationship or arrangement with the scheme (multi-employer CDC schemes only)	Scheme proprietor		Trustees
7B: The scheme proprietor ends the relationship or arrangement with the scheme (multi-employer CDC schemes only)	Scheme proprietor		Trustees
8: A person decides that the scheme should become a closed scheme (where the person making the decision has the power to do so under the scheme rules)	Employer/relevant former employer Trustees [Scheme proprietor] Other decision-makers				Employer/relevant former employer Trustees [Scheme proprietor]
9: An event occurs which is required or permitted by the scheme rules to result in the scheme becoming a closed scheme	Trustees		Employer/relevant former employer [Scheme proprietor]
10: The trustees decide that the scheme is at risk of failure and need to pursue one of the continuity options (multi-employer CDC schemes only)	Trustees		Scheme proprietor

7. A triggering event will also arise where there is a warning notice about a decision to withdraw a scheme’s authorisation (or in some cases a determination about such a decision), or a notice from us that a scheme is not authorised. These do not have to be notified to us.

Other notifications about triggering events

8. Trustees must also notify an employer or former employer within 14 days of the event (or of the trustees becoming aware of it).
9. Trustees must report:
   1. that the triggering event has occurred, unless the triggering event related to or was instigated by the employer or former employer
   2. the date on which the trustees intend to or did submit the implementation strategy to us
   3. that the implementation strategy will be made available to the employer or former employer within seven days after it has been approved by us⁵
10. An employer, former employer or other person to whom a triggering event relates or by whom it was instigated must notify the trustee of the triggering event within two days of it taking place⁶.

Implementation strategy following a triggering event

11. If a triggering event occurs, the trustees must produce an implementation strategy⁷. This is a plan for how the trustees will implement their chosen continuity option and should be a more detailed version of the higher-level plan in the continuity strategy.
12. The implementation strategy must be submitted to us for approval within 28 days of the triggering event occurring or the decision to withdraw authorisation becoming final in the case of a type 1 or type 2 triggering event⁸.

Content of an implementation strategy

13. The implementation strategy must be presented in writing in an accessible format and must include the information in regulations⁹ and must¹⁰:
    1. show that the trustees have carefully considered and applied the requirements of the Pension Schemes Act 2021 and Regulations, as well as the provisions of the code
    2. contain an analysis of the risks to members’ benefits, and provide adequate mitigations
    3. set out an appropriate and realistic timescale for dealing with the triggering event in relation to the chosen continuity option
    4. explain why the chosen continuity option is being pursued
    5. where the trustees have decided to pursue continuity option 2 (resolving the triggering event), set out in detail the conditions and timescales that may lead the trustees to instead pursue continuity option 1 (discharge of liabilities and winding up) or continuity option 3 (conversion to closed scheme)
    6. where the trustees have decided to pursue continuity option 1 (discharge of liabilities and winding up), include details of the receiving scheme and any other retirement vehicle the trustees intend to transfer members to
    7. provide details of the plan for calling on the financial reserves to cover the costs of complying with the relevant continuity option, including actuarial, legal and other service provider requirements
    8. wherever the implementation strategy includes cost estimates, include a statement of the factors that may cause these estimates to vary, and by how much

Charges

14. The implementation strategy must¹¹ set out a statement of administration charges calculated using the method in regulation 27, and include:
    1. the lower of the administration charges for the year before and the year of the triggering event, and not impose any additional administrative charges beyond those allowed for in the regulations
    2. the reason for imposing any additional or third party charges

Reporting

15. During a triggering event period, the trustees must submit periodic reports to us. The first report is due within 14 days of notification that their implementation strategy has been approved¹².
16. We will notify the trustees of the timing for the second and subsequent reports¹³ and may ask for more information. When trustees report on the implementation of the communication plan, we will assess how they are monitoring how well members understand their options.
17. Under continuity option 2, when trustees consider that the triggering event has been resolved, they must notify us with an explanation within 14 days¹⁴.
18. Under continuity option 3, trustees will need to inform us within 28 days when they consider the preparations for closing the scheme are complete¹⁵.

Legal references

¹ Section 39(1) of the Pension Schemes Act 2021

² Regulation 26 of the 2022 Regulations

³ Section 31 of the Pension Schemes Act 2021

⁴ Section 33 of the Pension Schemes Act 2021

⁵ Regulation 25(2) and (3) of the 2022 Regulations

⁶ Items 6 and 8 of the triggering event table at Section 31(4) of the Pension Schemes Act 2021

⁷ Sections 33(3), (3A), and (4) of the Pension Schemes Act 2021 and Regulation 25(2)(b) of the 2022 Regulations

⁸ Section 33(9) of the Pension Schemes Act 2021 and Regulation 25(2)(c) and (3)(c)(ii) of the 2022 Regulations

⁹ Sections 39(1)(a) and 40 (6) of the Pension Schemes Act 2021, Regulation 28 of the 2022 Regulations, and Regulation 51 of the 2025 Regulations

¹⁰ Section 40 of the Pension Schemes Act 2021

¹¹ Sections 40 (3) and (4) of the Pension Schemes Act 2021

¹² Section 43(2) of the Pension Schemes Act 2021 and Regulation 32(1) of the 2022 Regulations

¹³ Section 43(3) of the Pension Schemes Act 2021

¹⁴ Section 37(2) of the Pension Schemes Act 2021 and Regulation 30 of the 2022 Regulations

¹⁵ Section 38(2) of the Pension Schemes Act 2021 and Regulation 31 of the 2022 Regulations

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