Applying for authorisation

CDC code in force: 31 July 2026

1. The application for authorisation must be submitted by the trustees in our required format. The application forms will provide guidance on the evidence that must be submitted.
2. The trustees must satisfy us that the scheme meets the authorisation criteria:
   1. If we are satisfied that the authorisation criteria are met, we must authorise the scheme¹.
   2. If we are not satisfied that a scheme meets all the criteria, we must refuse to authorise it².
3. If we decide not to authorise a scheme, we will give reasons, and you may refer the decision to the tribunal³.
4. Once authorised, we must remain satisfied that a scheme continues to meet all authorisation criteria. If we cease to be satisfied, we may decide to withdraw the scheme’s authorisation⁴.

What to include in the application for authorisation

5. Trustees must include the following in their application⁵:
   1. The name of the scheme.
   2. The name of the employer that established the scheme (if any), and any other employers in the scheme.
   3. The approximate date from which the scheme intends to begin operating (for multi-employer CDC schemes only: this must be no more than 24 months from the application date).
   4. Contact details of the individuals making the application.
   5. A copy of the rules of the scheme and a copy of the scheme’s trust deed.
   6. A viability report, a viability certificate, and a continuity strategy.
6. For multi-employer CDC schemes only, the following must also be included with 
   the application⁶:
   1. The scheme’s business plan.
   2. The scheme’s latest accounts (if any).
   3. The scheme proprietor’s latest accounts (if any).
   4. The latest accounts of any undertaking (other than an unincorporated association) that partly or completely funds the scheme proprietor.
   5. A statement signed by the trustees of the scheme confirming that the scheme has a single scheme proprietor that meets the requirements set out in section 14C of the Pension Schemes Act 2021.
   6. A statement signed by the trustees of the scheme confirming that no trustee promotes or markets the scheme or acts as the chief financial officer of the scheme.
7. If there has been no promotion or marketing of the scheme and there is no intention to do any in the future, a statement must be provided, signed by the scheme proprietor, that confirms this fact and explains how and why this is the case⁷.
8. If there has been, or is intended to be, marketing and promotion of the scheme you must include⁸:
   1. details of any promotion or marketing of the scheme
   2. details of the matters set out in Part 1 of Schedule 1C to the Pension Schemes Act 2021 (no promotion or marketing that is unclear or misleading)
   3. details of the matters set out in Part 2 of Schedule 1C to the Pension Schemes Act 2021 (promotion or marketing: systems and processes), including details of the systems and processes used, or intended to be used, for the purposes of promotion and marketing of the scheme

Authorisation criteria

9. To authorise a CDC scheme, we must be satisfied that⁹:
   1. the scheme satisfies the definition of a collective money purchase scheme under section 1(2) of the Pension Schemes Act 2021 (Collective money purchase benefits and schemes) and the requirements of section 3 of the Pension Schemes Act 2021(Qualifying schemes)
   2. those involved in the scheme are fit and proper persons
   3. the design of the scheme is sound
   4. the scheme is financially sustainable
   5. the scheme has adequate systems and processes to communicate with members and others
   6. the systems and processes used in running the scheme are sufficient to ensure that it is run effectively
   7. the scheme has an adequate continuity strategy
10. For multi-employer CDC schemes only, we must also be satisfied that¹⁰:
    1. the scheme has a single scheme proprietor that meets the relevant requirements¹¹
    2. the trustees of the scheme do not promote or market the scheme
    3. the trustees do not act as chief financial officer of the scheme
    4. there are adequate systems and processes for ensuring that promotion and marketing in relation to the scheme is clear and not misleading¹²
    5. no person has carried out promotion or marketing in relation to the scheme that is unclear or misleading that has not been rectified
11. Multi-employer CDC schemes should also detail how the trustee has set the parameters that, if breached, would require a new CDC section to be opened.

Application timeline

12. Trustees can apply for authorisation at any time. However, we strongly encourage trustees and, in the case of a multi-employer CDC scheme, the scheme proprietor, to engage with us before submitting a formal application.
13. Where a scheme or section intends or is required to add a new section, we expect trustees to engage with us as soon as they become aware of this.
14. We will consider that an application has been made once we have received:
    1. a completed application form
    2. supporting evidence for each of the authorisation criteria
    3. the application fee
15. We will check that the application is complete and tell you within seven days if anything is missing.
16. Once we are satisfied we have received a complete application, we will inform you that the assessment period began on the date the application was submitted. We must tell you within six months of this date whether the scheme has been authorised¹³. Once authorised, a multi-employer CDC scheme will normally have 24 months from the application date to start operations.
17. During the assessment period we may ask for information or clarification. We recognise that circumstances (such as corporate activity in the employer or a change of trustee) may require you to update your application during the assessment period. Any changes should be sent to us, with reasons, as soon as possible. We are more likely to be able to take account of changes or new information if we are notified earlier in the assessment process.

Application fee

18. A standard non-refundable application fee is set out in the regulations (£77,000 at the time of publication) and must be paid by BACS transfer for us to confirm we have received a completed application¹⁴.
19. If an application is withdrawn during assessment and then resubmitted, the resubmission will be treated as a new application and the full standard fee or specified fee must be paid for it.

Legal references

¹ Section 9(4) of the Pension Schemes Act 2021

² Section 9(5) of the Pension Schemes Act 2021

³ Section 10 of the Pension Schemes Act 2021

⁴ Section 30(1) of the Pension Schemes Act 2021

⁵ Section 8(30 of the Pension Schemes Act 2021, Regulation 6 of the 2022 Regulations, and Regulation 29 of the 2025 Regulations

⁶ Section 8(3) of the Pension Schemes Act 2021 and Regulation 29 of the 2025 Regulations

⁷ Regulation 29(5)(a) of the 2025 Regulations

⁸ Regulation 29(5)(b) of the 2025 Regulations

⁹ Section 9(3) of the Pension Schemes Act 2021

¹⁰ Section 9(3) of the Pension Schemes Act 2021

¹¹ Sections 14B and 14C of the Pension Schemes Act 2021

¹² Section 14D(2) of the Pension Schemes Act 2021

¹³ Section 9(2) of the Pension Schemes Act 2021

¹⁴ Regulation 7(1) of the 2022 Regulations and Regulation 30(1) of the 2025 Regulations

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