Continuity strategy: overview

CDC code in force: 31 July 2026

1. The continuity strategy must be submitted as part of the authorisation application¹.
2. We must, at the time we consider an application for authorisation, be satisfied that the scheme has an adequate continuity strategy². This is a document that sets out how members’ benefits will be protected following a triggering event as detailed in Continuity strategy: Preparing for a triggering event.
3. A continuity strategy must, in the case of a single-employer CDC scheme, be prepared by the trustees³, setting out how members’ interests will be protected after a triggering event.
4. For a multi-employer CDC scheme, the continuity strategy must be prepared by the scheme proprietor⁴. The scheme proprietor module of this code explains who the scheme proprietor is and the nature of the role.
5. Once prepared by the scheme proprietor (in the case of a multi-employer CDC scheme), the continuity strategy must then be approved by the trustees as part of the application for authorisation. The scheme proprietor will regularly review the strategy and revise it as necessary⁵. It should be reviewed at least annually. Each revision must be approved by the trustees⁶.
6. The statement of all levels of administration charges relevant to each continuity option should be included as part of the continuity strategy as a single document or provided as a standalone document in an electronic format that is Excel compatible, with clear data labels.
7. There is nothing preventing the trustees or scheme proprietor from including the continuity strategy as part of the scheme’s business plan. Where they choose to do this, the continuity strategy should be a clearly identifiable and distinct part of the wider business plan.
8. It must give details about all matters set out in regulations⁷ and include a statement of all levels of administration charges⁸, which may be presented as a separate document.
9. We do not expect the continuity strategy to be exhaustively detailed. Using the headings below as a guide, it should provide the principles and framework for identifying key actions, their owners and the timings of decisions required to deal with a triggering event. It should be sufficiently comprehensive for trustees to be able to quickly resolve which continuity option to select and be in a position to provide a template for working up the detail of an implementation strategy within 28 days of the triggering event occurring or becoming final. We would also be likely to consider a review of the continuity strategy following a significant event that has been approved by the trustees of a multi-employer CDC scheme⁹ to be a reasonable precaution.
10. While the continuity strategy should be thought of as setting out a business case to explain what needs to be done and how, and the likely cost of dealing with a triggering event, the implementation strategy is a fully costed operational business plan to manage a triggering event once it has occurred.
11. The continuity strategy should be flexible enough to allow the trustees to tailor their approach in response to a specific triggering event. It should be periodically reviewed and, if appropriate, revised to adjust to changing circumstances. It should also give sufficient detail to allow calculation of the costs identified for the costs, assets and liquidity plan (CALP).
12. In addition to meeting the continuity strategy requirements set out in the legislation¹⁰, trustees should be clear about how they will:
    1. be adequately prepared in case of a triggering event occurring
    2. continue to operate the scheme during a triggering event period
    3. decide which continuity option to pursue
    4. meet the costs of dealing with a triggering event
    5. communicate with members

Legal references

¹ Section 8(3)(b) of the Pension Schemes Act 2021

² Section 9(3)(f) of the Pension Schemes Act 2021

³ Section 17(2)(a) of the Pension Schemes Act 2021

⁴ Section 17(2)(b) of the Pension Schemes Act 2021

⁵ Section 17(6A) of the Pension Schemes Act 2021

⁶ Section 17(6B) of the Pension schemes Act 2021

⁷ Regulation 15(1) of the 2022 Regulations and Regulation 38(1) of the 2025 Regulations

⁸ Regulation 16 of the 2022 Regulations and Regulation 39 of the 2025 Regulations

⁹ Section 17(6B) of the Pension Schemes Act 2021

¹⁰ Section 17 of the Pension Schemes Act 2021

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