Member communications

CDC code in force: 31 July 2026

Member communications¹

Effective communications are necessary to the success of a CDC scheme. Members need to understand the risks and benefits of the scheme, as well as having clear and accessible information on how their benefits may increase or decrease.
There should be a focus on producing member communications as well as the IT functionality needed. We will assess the functionality, quality and maintenance of the IT systems used for member communications on the same basis as the IT systems more generally.
In multi-employer CDC schemes, member communications should be consistent with any promotional or marketing material that has been used to induce prospective or existing employers to join or remain within the scheme.
To produce effective communications, there must be:
1. appropriate systems and processes in place
2. individuals who have appropriate skills to undertake the planning and assessment work²
In assessing the scheme, we are more likely to be satisfied where the following matters are addressed.

There is a person with overall responsibility for member communications.
There are individuals employed or contracted who have the appropriate skills to develop, assess and implement effective communications. If communications are outsourced, we expect the same due diligence to be conducted as for other external service providers.
The individuals providing communication, information or expertise have enough capacity to do that work.

There is a plan for producing and issuing member communications.
The plan sets out activities for the year and must cover reviews of member communications, member engagement and reporting.
We do not expect all scheme communications to be reviewed each year, but there should be regular reviews of key communications that impact members.
The plan includes a mechanism to measure the effectiveness of the member communications in increasing member engagement with the scheme (for example, developing an engagement dashboard).
The plan covers all new and existing legal requirements on member communications, including the provision of annual benefit statements to members³.
The plan sets out what resources will be required for each communication, for example actuarial, legal, administration, employer and representative bodies, such as unions.
The plan sets out when those resources are likely to be required and records any capacity or other constraints on those providing the information or expertise.
The plan includes the scheme actuary’s annual review for the viability certificate.

There is an evidence-driven process for creating, reviewing (including that the content is accurate and not misleading) and maintaining member communications in a timely manner.
There is evidence that the distribution channels used are appropriate and accessible for the membership.
Feedback is considered from, where applicable, trustees, employers, members, and unions or other representative bodies.
There is evidence of how the process has been used to develop key communications, such as the member booklet and annual benefit statement.

Members are actively encouraged to give feedback on communications and raise concerns.
There are clear and simple channels for members to give feedback.
As part of the process of developing and routinely maintaining communications, views must be sought from a range of members who are representative of the membership as a whole.
This process needs to test whether that range of representative members can understand the communication, including the description of any impact on their benefits and the level of risk involved. We will also want to understand how this work will be used to improve the effectiveness of member communications.
There is evidence of the methods used to gather member feedback and its outcomes. This could include surveys to establish members’ understanding of the risks and benefits.
Where ad hoc feedback is received from members, it must be considered and, where appropriate, acted on.

A report should be provided to the trustees on how feedback from members has been taken into account. This report should be provided quarterly, or at a different frequency to align with trustee meetings.
The report to trustees should:
1. summarise the feedback from members (unless no feedback has been received in that quarter) and whether it was proactively sought from members or whether concerns had been raised by members
2. set out any complaints received in respect of member communications
3. set out how the feedback has been considered and what action will be taken
4. set out the rationale for making changes (or not)
The purpose of the report is to enable trustees to monitor progress against the communications plan and identify any additional actions needed, including by the scheme proprietor, such as improvement of processes for future communications.
A report should be provided to members on how their feedback on communications has been taken into account.
This report should be provided at least annually.
The report to members should:
1. summarise the feedback from members and any action that has been taken in response
2. explain why changes have or have not been made
3. summarise any planned work on communications over the next reporting period
4. explain the importance of members reading and understanding communications from the scheme, and how they can raise concerns and give feedback

¹ Sections 9(3)(ca)(i) and 15 of the Pension Schemes Act 2021 and Schedule 4 to the 2022 and 2025 Regulations

² Paragraph 4 of Schedule 4 to the 2022 Regulations and Paragraph 3 of Schedule 4 to the 2025 Regulations

³ Paragraph 17A and Schedule 6A to The Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013

⁴ Paragraph 6(d) of Schedule 4 to the 2022 Regulations and Paragraph 5(d) of Schedule 4 to the 2025 Regulations