Promotion and marketing of multi-employer CDC schemes

Practical guidance on meeting the authorisation criteria on promotion and marketing set out in our collective defined contribution (CDC) code of practice.

Published: 31 July 2026

Who this guidance is for

This guidance is for scheme proprietors, trustees and any other roles involved in the promotion or marketing of a multi-employer CDC scheme. This guidance is not relevant to single-employer CDC schemes as they do not need to meet the authorisation criteria on promotion and marketing.

Where we refer to a multi-employer CDC scheme, this also includes a multi-employer CDC section of an occupational pension scheme.

On this page

Overview

The CDC code sets out our expectations on promotional and marketing activities. This guidance provides further clarity on some of those expectations, including practical examples. It does not replace the need for professional advice but can be used in conjunction with any advice received.

We intend to review and update this guidance as the market develops and in relation to emerging trends we observe during the authorisation and supervision of CDC schemes.

How we define promotion and marketing activity

We are likely to consider any communication to employers as promotion or marketing where they invite or induce participation in, or transfers into, a CDC scheme. Any promotion or marketing of multi-employer CDC schemes must enable current and prospective employers to make informed, balanced and realistic decisions. These decisions have a long-term impact on members and are irreversible 

Principles for promotion and marketing 

• The key principle for all promotional or marketing items is that they must be clear and not misleading.
• Where promotional or marketing items are considered unclear or misleading or both, there should be appropriate rectification.

The following additional principles apply depending on the nature of the promotional or marketing item. It is the responsibility of the scheme proprietor to determine which, if any, need to be complied with:

• Present benefits and risks with equal prominence.
• Be accurate and based on reasonable assumptions.
• Provide sufficient, complete and transparent information to support informed decision-making.
• Ensure key risks are clearly stated and prominently displayed.
• Be appropriate for the intended audience and promotional channel.
• Avoid implying certainty, guarantees, or that outcomes are typical.
• Be subject to robust governance, including independent approval and audit trails.
• Be standalone compliant, without relying on other materials for balance or context.

Roles and responsibilities in promotion and marketing

Scheme proprietor 

We expect the scheme proprietor to be responsible for the promotion or marketing of the scheme even if this responsibility is outsourced to a competent third party.

We do however recognise that each scheme proprietor will have set up their operations in a way that works for them. As a result, there may not be a job title that covers the approvals function for promotion and marketing. For example, the scheme proprietor may employ a compliance officer who would be responsible for the overall functioning of the scheme from a regulatory perspective, with promotional or marketing approvals being part of their remit. Alternatively, responsibility for promotion or marketing may be split across more than one role (for example, a compliance role and a marketing role). Whatever the set-up, the authorisation application should clearly explain this.  

Trustees

The trustees are responsible for the governance and oversight of the scheme in line with the legislative framework and the CDC code but are prohibited from marketing or promoting the scheme. Their role includes ensuring:

• the scheme is run in the interests of its members
• that risks are appropriately managed
• that any communications to members meet the requirements set out in the Systems and processes: Member communications module of the CDC code 

In addition, they should have the opportunity to see some of the promotional material produced by the scheme proprietor and challenge the contents if they feel items are potentially unclear or misleading. We do not expect all promotional items to be viewed by the trustees, but it would be good practice for trustees to view any items deemed to be higher risk, such as promotional scheme launch items.

How trustees can speak to employers

While trustees are prohibited from promoting or marketing the scheme, they may engage with participating and prospective employers to explain:

• how the scheme operates
• the governance framework
• the respective responsibilities of employers, trustees and the scheme proprietor

For example, we would not be concerned about them providing the following factual information to employers:

“The [scheme name] is a collective defined contribution (CDC) pension scheme. In a CDC scheme, contributions are defined and members’ benefits are paid from a collective pool of assets. Benefits are not guaranteed and will be increased or decreased each year to bring the value of the scheme’s liabilities into line with the value of its assets.”

Additionally, we would not have any concerns if trustees use the scheme proprietor’s logo and contact details in any statements they make. However, they should not provide statements that could be seen as promotional alongside it (this is known as image advertising). The clear and not misleading principles would also still apply.

Even factual sounding material will become a promotion if it:

• encourages joining, transferring, or remaining in a CDC scheme
• suggests CDC is better, more suitable, or preferable
• quotes expected income levels, illustrations, or comparative outcomes
• refers to ‘value’, ‘returns’, ‘benefits’, or ‘outperformance’ in a persuasive way
• is framed around employer decision making (for example, “Is CDC right for your employees?”)

Example: Trustees engaging with prospective employers

Good practice

Trustees are invited to a meeting with a prospective employer. During the session they:

• explain, in neutral terms, how CDC schemes operate, the governance framework and the respective roles of trustees and the scheme proprietor
• use factual statements drawn from scheme documentation without encouraging participation or transfers
• direct the employer to the scheme proprietor for any promotional materials or commercial discussions

Why this is good practice

Trustees stay within their permitted role of explaining how the scheme operates without promoting or marketing it. 

Poor practice

Trustees are invited to a meeting with a prospective employer. During the session they describe the scheme as:

“An excellent opportunity for employers looking to provide a better pension than DC at no extra cost.”

They also distribute a flyer encouraging the employer to join.

Why this is poor practice

The trustees are promoting the scheme in breach of the prohibition on trustees promoting or marketing the scheme. In positioning their CDC scheme as ‘better’ than DC schemes they are expressing a value judgement. This goes beyond their permitted role, and they are likely to have carried out promotion or marketing of a scheme which is also unclear and misleading. 

Approval of promotional and marketing material

We expect the person responsible for promoting or marketing the scheme (such as the scheme proprietor) to have a documented approvals process in place. This should help identify and minimise the risk that they carry out any unclear or misleading promotion or marketing. A copy of this process should be submitted to us at authorisation stage, along with details of the systems and processes used to document, track and evidence the approvals. The appendix contains an example approvals process for promotion or marketing material.

Comparisons with other schemes

If marketing or promotional material contains any comparison with another type of pension scheme or pension product (such as a competing multi-employer CDC scheme, defined benefit scheme, defined contribution scheme (including DC drawdown) or annuities), it must be clear and balanced. This means that material differences in benefit structure, flexibility and risk must be clearly explained. We do not expect CDC to be positioned as a universal or default ‘better’ option. However, we appreciate that schemes may wish to explain the potential outcomes from risk and longevity pooling and therefore can refer to material already in the public domain to demonstrate this. Any quoted figures must be fully substantiated along with assumptions used, and a copy of this material must be retained on the approval file. Schemes should also keep the substantiation material under regular review to ensure only the most up to date figures are used to avoid their promotional material becoming misleading.

Balancing the benefits and risks of the scheme

CDC promotional or marketing material must present benefits and risks with equal prominence. For example, you may like to explain the following benefits of a CDC scheme:

• Income is paid for life.
• Collective investment and longevity risk pooling is expected to decrease volatility and lead to better member outcomes.
• The scheme will have professional governance and decumulation management.

To ensure the above benefits are balanced, we expect you to include an explanation of the relevant risks and limitations in the material. For example:

• Pension income can go down as well as up.
• There is no guarantee that a particular level of benefit will be paid.
• Downwards adjustments may occur following adverse investment experience. 
• Members have limited individual control compared to DC pensions.
• An explanation of any restrictions on transfers out and where allowed, that transfers out may be subject to valuation uncertainty.

Details of the risks must not be hidden in footnotes, hyperlinks, or small print and must be as equally prominent as the benefits of the scheme. 

Example: Employer brochure for a multi employer CDC scheme

Good practice

A scheme proprietor produces a brochure aimed at prospective participating employers. The brochure:

• clearly explains how a CDC scheme works, including that contributions are defined and benefits are not guaranteed
• presents benefits (for example, income paid for life, collective risk sharing, professional governance) and risks (for example, income can go down, no guarantees, limited individual control) with equal prominence and similar visual weight
• includes a clearly worded risk warning on the same page as the benefits, in plain language and not hidden in footnotes
• avoids describing CDC as ‘better than’ other pension options, instead explaining the key differences between CDC, DC and DB in a balanced way
• has been through a documented approval process involving technical input and independent sign off, with a fully documented audit trail 

Why this is good practice

The material is clear, accurate and not misleading, enables informed decision making, and follows the expectations on balancing benefits and risks, comparisons, and governance of approvals set out in this guidance. 

Poor practice

A marketing leaflet sent to employers focuses heavily on ‘stable income’ and ‘smoother pensions than DC’, with:

• only a brief reference to risks in small print on the back page
• no explicit statement that benefits are not guaranteed or may be reduced
• headline statements implying CDC delivers outcomes similar to DB without explaining the absence of guarantees
• no evidence of independent approval or technical review

Why this is poor practice

The leaflet emphasises benefits without equal prominence of risks, creates potentially misleading comparisons with other schemes, and fails to meet the ‘clear and not misleading’ standard expected for CDC promotional material. 

Accuracy of projections, examples and illustrations

Where illustrations or income examples are used:

• They must be clearly identified as illustrative only.
• Assumptions (for example, investment returns and future adjustments) must be reasonable and adequately explained.
• Promotional material must not imply that projected outcomes are likely or guaranteed.

Promotions should avoid:

• using unrealistic assumptions (for example, using overly optimistic assumptions, or reflecting outcomes better than most customers would actually experience) and presenting them as typical outcomes
• comparisons with annuities or drawdown that omit material differences in risk or certainty

Example: Use of income projections and illustrations in employer promotions

Good practice

Promotional material aimed at employers includes an income illustration that:

• is clearly labelled as ‘illustrative only’
• explains the assumptions used (investment returns, future adjustments)
• states explicitly that outcomes may differ and that income can go up or down
• avoids presenting a single optimistic scenario as representative

Why this is good practice

The material meets expectations on accuracy, transparency of assumptions and avoidance of implied guarantees or typical outcomes. 

Poor practice

Promotional material aimed at employers includes a single projected pension figure described as:

• “What you can expect to receive at retirement.”
• No assumptions or caveats are provided.

Why this is poor practice

This implies certainty and likely outcomes, which is misleading for a CDC scheme and contrary to the guidance on projections and illustrations. 

Social media platforms

Our expectations on promotion or marketing are neutral as regards the media channel and the technology used. They apply fully to social media platforms, including formats such as short-form video. Promotions through social media can reach a wide audience very quickly. This means it’s important to consider how any promotion may be used and that it could be seen by a wider audience than anticipated, which may include unintended recipients.

The following examples are likely to be considered promotion or marketing of a CDC scheme:

• Posts encouraging individuals to join a CDC scheme or transfer their pension benefits into a CDC scheme.
• Statements emphasising income stability, ‘smoother pensions’, or comparisons with DC.
• Paid for or sponsored content by employers, influencers or affiliates.  

Purely factual, neutral messages (for example, explaining how CDC works) are less likely to be promotions but still need to be clear and not misleading.

Additionally, it’s important to assess whether a platform is appropriate for the complexity of the message:

• Short form content on social media may not provide sufficient space and time to explain CDC risks adequately.
• Video content must include on screen risk warnings and/or spoken risk warnings that are visible for long enough to be read and understood and spoken slowly enough to be understood.
• Any graphics and charts must avoid selective presentation of favourable scenarios.

Example: Social media promotion

Good practice

A scheme proprietor posts a short video on a social media platform explaining what a CDC scheme is. The video:

• uses neutral, educational language
• includes clear on screen risk warnings that remain visible long enough to be read
• avoids calls to action, such as “join now” or “transfer today”

Why this is good practice

The video is factual rather than promotional and appropriately considers the limitations and risks of using short form social media platforms. 

Poor practice

A scheme proprietor posts a short video on a social medial platform stating:

• “CDC pensions mean no stock market stress and reliable income for life.”
• Risk warnings are included in small text at the bottom of the screen and not displayed long enough to be read in full.

Why this is poor practice

Short form content does not adequately explain the risks, the messaging is unbalanced and the risk warnings are not sufficiently prominent. This makes the promotional video misleading.

Appendix: Example promotion or marketing approvals process

Purpose

This process is designed to ensure that all promotional and marketing materials are clear and not misleading and that there is appropriate oversight and audit trails throughout the approval process. Where we use the term ‘approvals person’, this is a catch all term to include all roles responsible for approving promotional and marketing material (for example, the scheme proprietor or compliance officer).

Step 1: Development of material

The marketing team develops the initial leaflet, brochure, poster or other promotional material (the ‘originator’). The originator is responsible for drafting the content in line with agreed messaging principles and internal standards.

Step 2: Initial technical and product sense check (where applicable)

Where the material contains scheme specific information, best practice is for the originator to share the draft with relevant stakeholders, such as:

• the scheme actuary
• the product team
• any other internal or external advisers that work closely with the scheme proprietor for example, legal, compliance or technical personnel

The purpose of this stage is to enable a review to confirm that:

• factual statements are correct
• the content is clear and balanced
• nothing is potentially misleading when read in context

Reviewers provide feedback to the originator, who incorporates any agreed changes before progressing to formal approval.

Step 3: Submission for independent approval

Once any initial revisions are complete, the originator submits the material to the approvals function.

The approvals role should sit outside of the marketing team to minimise conflicts of interest and support independent judgement.

Step 4: Formal approval review

The approvals person undertakes a full review of the material, considering whether it:

• is clear and not misleading
• presents scheme features and risks appropriately
• aligns with applicable governance and regulatory expectations

Following review:

• If approved: the approver confirms that the item is approved for use.
• If changes are required: the approver returns the material to the originator, clearly stating what changes are required and the reasons for them.
• If rejected: the approver explains why the item cannot be approved in its current form.

Step 5: Remediation and resubmission

Where changes are requested or the item is rejected:

• The originator makes the required amendments.
• The revised version is resubmitted to the approvals person for further review.

This cycle continues until the material is either approved or formally withdrawn.

Step 6: Recording and audit trail

Once approval is granted, the hardcopy file or system is updated with key approval details, for example:

• name of approver
• all comments and changes
• version number
• date of approval
• scope of approval (including expiry date)

This ensures a clear end to end audit trail of the review and approval process.

Step 7: Final record-keeping

The final approved version of the material is:

• either stored as a hard copy within the scheme’s filing system or as a digital copy on the scheme’s IT system
• retained in accordance with document retention policies

Only the approved version may be issued or used.

All promotional or marketing material must be standalone compliant. This means that each item must meet our expectations as set out in the CDC code when considered individually.

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