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COVID-19: an update on reporting duties and enforcement activity

Reporting requirements for those running a pension scheme that were paused in response to COVID-19 will resume from 1 July.

As a result of the COVID-19 situation we have been adopting a more flexible approach to what we expect you to report in a number of areas, and when enforcement action would be appropriate. We will continue to assess breaches of administrative and compliance requirements on a case-by-case basis and respond pragmatically where these breaches are COVID-19 related.

The Pensions Ombudsman has confirmed it will take into account our latest guidance on COVID-19 issues if it receives complaints about delays caused by COVID-19 circumstances. Read The Pensions Ombudsman statement on COVID-19.

Published: 9 April 2020.

Last updated: 16 June 2020.

16 June 2020: Updated with reporting requirements changes from 1 July.

Reporting requirement changes - trustees and administrators

Due to the COVID-19 situation we had paused certain reporting requirements for trustees and administrators. From 1 July, reporting requirements will resume as normal, including for:

  • Suspended deficit repair contributions - trustees will need to submit a revised recovery plan or report of missed contributions
  • Late valuations and recovery plan not agreed
  • Delays in cash equivalent transfer quotations and payments
  • Failure to prepare audited accounts
  • Master trusts, where we expect formal reporting to resume

Reporting late payment changes - pension scheme providers

There is one exception to the return to business as usual on reporting: providers will continue to have 150 days to report late payments of contributions (other than deficit repair contributions), where normally we require information on late payments within 90 days. We will review this easement again at the end of September.

Enforcement - chair’s statements and failure to prepare audited accounts

We will continue not reviewing any chair’s statements that we receive until after 30 September 2020. Any chair’s statements we receive (including in relation to master trusts) will be returned unread, so this should not be taken as any indication that the statement in question complies with the requirements.

Whilst we will take a pragmatic approach to late preparation of audited accounts and will accept delays to 30 September, the legislation on chair’s statements does not give us any discretion about imposing fines where the trustees have not prepared the chair’s statement (which must be included in the annual report and accounts, but can be prepared and signed off separately) on time.

Enforcement - investment governance

We do not expect to take regulatory action if a review of a statement of investment principles (or statement in relation to any default arrangement) is not delayed beyond 30 September 2020.

Schemes in Relationship Supervision

Many relationship-managed schemes will have already spoken with their named supervisor. In light of the current exceptional events, we are refocusing our relationship-managed supervisory activity, focusing more on near-term risks rather than the standard activities in our supervisory cycle. We will be speaking to schemes we have assessed as presenting risks directly to better understand their position and the risks and issues that have arisen.

If you have immediate concerns due to the current situation, please contact your named supervisor to discuss.

Other schemes

We will continue to take a risk-based approach in our regulatory activity, reviewing and assessing incoming requests against a range of risk indicators.

Please contact us via if you require assistance. Given the current circumstances, please use email rather than write by post, if at all possible.