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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 resumed from 1 July.

As a result of the COVID-19 situation we had 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. Reporting should now be back to normal.  

In deciding whether to take enforcement action, we will assess breaches of administrative and compliance requirements on a case-by-case basis and respond pragmatically where you can demonstrate COVID-19 related reasons for any breaches.

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: 8 June 2021

  • 8 June 2021: Updated Schemes in Relationship Supervision section
  • 16 June 2020: Updated with reporting requirements changes from 1 July
  • 16 September 2020: Updated with reporting requirements changes from 1 January 2021
  • 24 September 2020: Updated Schemes in Relationship Supervision section

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 resumed 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 be resumed

Outstanding payment reporting: change to COVID-19 information for providers

From 1 January 2021, we are asking pension scheme providers and trustees to revert to reporting payment failures that are 90 days outstanding, rather than 150 days, as set out in code of practice 5 for occupational pension schemes and code 6 for personal pension schemes.

We expect all schemes to return to 90 day payment failure reporting as soon as possible after 1 January. However, we acknowledge that this change back to business as usual will have an impact on providers’ systems and processes, so we are allowing up to 1 April for schemes that may need the extra time to make the necessary adjustments and work with employers to bring any outstanding contributions up to date. 90 days reporting will become mandatory for all providers from 1 April.

The temporary easement to reporting outstanding payments at 150 days, rather than 90, only ever applied to payment failures that were material because they were outstanding for a certain period – providers should continue to report all and any other payment failures as set out in the codes of practice 5 and 6 via the Maintaining Contributions Portal.

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

We will revert to reviewing chairs’ statements submitted on and after 1 October 2020 as usual (unless we specifically notify you otherwise). Any chair’s statements we receive before 30 September 2020 (including in relation to master trusts) will be returned unread, so this absence of comment should not be taken as any indication that the statement in question complies with the requirements.

Please note that the legislation on chair’s statements does not give TPR any discretion about imposing fines where we are notified, or form the view, that the trustees have not prepared a compliant chair’s statement on time.

In light of this, we will not be publishing details of chair’s statement fines in the penalties section of our website at the time of the next C&E bulletin. We will revisit this decision for future issues as the situation develops and may revert to our usual approach in situations where we feel it is appropriate. 

Please note that our normal approach to enforcement in relation to late preparation of audited accounts will resume from 1 October. 

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.  From 1 October 2020 our normal approach to enforcement will resume.

Schemes in Relationship Supervision

We scaled down our relationship supervision programme throughout the pandemic to allow us to focus our efforts on supporting schemes and employers experiencing financial distress.

The pensions landscape has shifted since March 2020, and we are refocusing our supervisory regime accordingly. As the schemes we currently supervise are all at different points on our supervisory cycle, we will contact them individually to determine the next steps. If you have immediate concerns due to the ongoing 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.