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COVID-19: an update for trustees, employers and administrators

These are unprecedented, challenging and uncertain times for trustees, employers, administrators and, crucially, savers.

There are different pressures on different areas of the pensions system.

We have provided guidance below for those we regulate and work with.

This page will be updated over the coming weeks as we respond to feedback, intelligence and the evolving risks.

Published: 20 March 2020.

COVID-19 (coronavirus)

Trustees of both defined benefit (DB) and defined contribution (DC) schemes, employers and administrators should focus their activities on the key risks to pension savers:

  • benefits need to be paid
  • the risk of scams needs to be minimised
  • employers need to continue contributing
  • savers need support to make good decisions in these challenging circumstances
  • some administrative breaches of the law may occur and we will maintain a proportionate and fair approach to any action we may take

We are closely monitoring the COVID-19 situation, and working collaboratively with government, regulators and other bodies to assess the most immediate risks to pension schemes.

Our expectations of trustees

You need to be alive to risks that would have significant consequences for your scheme and members. Assess whether your business continuity plan (BCP) is still adequate and contact your administrator or service provider to find out what contingency is in place to mitigate their impact of increases in work volumes or unavailable staff.

You should make it clear which activities should be prioritised in the event of under-resourcing, such as pensioner payments, retirement processing and bereavement payments. Confirm this priority order with your administrators or providers and work with them if there are any issues with these activities.

If you are the trustee of a DB scheme and your sponsoring employer is at risk, or has asked you to reduce or suspend your scheme’s deficit repair contributions (DRCs), please read the page on corporate distress.

Helping protect your members from scams

Savers might increasingly look to transfer their pension, prompted by the instability of their employer or the financial markets.

This means they could be increasingly targeted by scammers attempting to lure them to ‘safe havens’. If a saver asks about transferring their pension, urge them to exercise extreme caution and visit ScamSmart which has specific guidance relating to COVID-19.

Trustees should also signpost their members to the Money and Pensions Service – particularly those approaching retirement and whose pension may have been affected by the current economic conditions.


COVID-19 is placing huge additional pressures on the administration of pension schemes. Administrators should prioritise payments of benefits, retirement processing and bereavement services, as well as any administrative functions required to support these. After this you should focus on the processes you need to ensure accurate benefits (eg investment of contributions).

We understand that many non-critical trustee and member services may be affected, for example you may have to delay responding to member queries or producing annual benefit statements.

Trustees and administrators should report to us immediately if they believe they will be unable to pay members’ benefits. Please report everything else to us as normal and we will take a pragmatic approach in our response.


We know this is a challenging time for everyone and we recognise the strain this is putting on employers.

We will take a proportionate and risk-based approach towards enforcement decisions, in light of these challenging times, with the aim of helping to get employers back on track and supporting both employers and savers.

The government has published information about support for employers, employees and businesses affected by COVID-19.

Timings of our regulatory communications, publications and events

We are temporarily suspending our regulatory initiatives. If you have been selected to take part, we will be in direct contact with you regarding our expectations and next steps. We will be maintaining one-to-one and relationship supervision and rapid response work to enable two-way contact with trustees, managers and sponsoring employers during this time – please contact your supervisor if you have any concerns. Further information can be found in supervision.

We are postponing the publication of our Corporate Plan, our long-term strategy, and our consultation on bringing together our codes of practice to form one single code. Our DB funding consultation is open, and we will review timings in the coming weeks.

We have cancelled or moved all scheduled events.

If you are in difficulty

Please contact us if you have immediate concerns with your scheme, administration or cannot pay your contributions:

Trustees and administrators contact us 

Employers contact us