Assessment of competence and experience

CDC code in force: 31 July 2026

1. In assessing whether a person is a fit and proper person to act in a particular capacity, we will take into account a person’s relevant skills, knowledge and experience.
2. We are more likely to be satisfied of an individual’s competence where they:
   1. hold relevant professional qualifications or accreditations
   2. have gained experience, over a number of years, which is relevant to the function being performed (for example experience of pension, financial or insurance businesses of a similar scale)
3. We are less likely to be satisfied where:
   1. experience is limited to small scale operations that are not related to pensions, financial or insurance business, for example a single retail outlet
   2. experience is in the relevant industry sector but unrelated to the function being performed
4. This should not stop a less experienced individual from taking on a new role, as long as they have a basic level of knowledge before they are appointed.
5. Where any of the roles are performed by a group of individuals, we are more likely to be satisfied where that group can demonstrate that the majority of individuals possess relevant business experience rather than this being concentrated in one or two individuals.
6. For multi-employer CDC schemes, the scheme’s business plan should explain:
   1. how it is intended to maintain and develop competence
   2. the succession plan for each role
7. We set out below the specific indicators of competence for each function.

Trustee competence

8. We will assess individual competence as well as the overall skills and experience possessed by the trustee board¹. We recognise that not all trustees will be experts, nor do they need to be, and we have set out below different levels of knowledge and experience that are more likely to satisfy us.
9. Where an individual has not previously been appointed as a pension trustee, or does not have sufficient experience through a previous appointment, we are more likely to be satisfied where there is evidence of the following:
   1. The individual has undertaken training to gain a basic level of knowledge before or at the time of their appointment as trustee, which is equivalent to the Trustee Knowledge and Understanding set out in legislation². This training should at least cover what occupational pensions are, understanding DB, DC and CDC schemes, the role of the trustee, running a scheme, pension law basics, and pension investment basics. This training could be undertaken through our Trustee toolkit or alternative provision.
   2. A plan is in place to build further knowledge.
10. Where an individual has previously been appointed as a pension trustee, we are more likely to be satisfied where there is evidence of the following:
    1. The individual has gained sufficient equivalent knowledge through previous experience as a trustee or in a senior role in a comparable scheme. By senior role we mean a role with accountability and responsibility for the day-to-day running of a scheme, including management, supervisory, technical or compliance oversight roles. By comparable scheme we mean an occupational scheme of similar size and complexity, but not necessarily a CDC scheme.
    2. The individual has gained sufficient experience through the Association of Professional Pension Trustees (APPT) or Pensions Management Institute (PMI) trustee accreditation.
11. For all individual trustees, we are more likely to be satisfied where:
    1. they have received scheme-specific training on CDC schemes, including what is being offered to members, the scheme design, key tasks in running the scheme and how multi-employer CDC schemes differ from single-employer CDC schemes
    2. they can demonstrate how they will continue to develop the relevant knowledge, skills and experience throughout supervision
12. In assessing the trustee board, we are more likely to be satisfied if the board:
    1. has the skills, knowledge, and experience appropriate for governing their CDC scheme
    2. has a balance of skills and experience across its members
    3. has a range of diverse skills and experience in senior roles, to include pensions, trusteeship, investment, administration, actuarial work, and communications
    4. has a plan for maintaining and developing the board’s skills, knowledge and experience
    5. has a plan to address any gaps in skills, knowledge and experience
    6. has processes and standards to ensure that individuals subject to contract, employment, or delegation themselves have relevant skills, knowledge, and experience
    7. ensures that any service provider’s staff have the necessary skills, knowledge, experience, and integrity

Competence of scheme proprietor (multi-employer CDC schemes only)

13. As part of the authorisation process, applicants will need to satisfy us that the scheme proprietor of a multi-employer CDC scheme is in a position to be able to perform their role to an adequate level.
14. A declaration as to the overall competence of the scheme proprietor, with particular reference to the experience, knowledge and professional qualifications of the individuals performing the functions of the scheme proprietor in the exercise of a management or executive role, and plans to improve that competence by way of continuous professional development or otherwise, must be included in the scheme’s business plan

Competence of persons who promote or market the scheme (multi-employer CDC schemes only)

15. We are more likely to be satisfied where they have:
    1. experience of carrying out this function in a relevant or regulated environment
    2. can provide evidence that they have experience of working with systems and processes designed to provide quality control and assurance of a promotional or marketing function

Competence of chief financial officer (multi-employer CDC schemes only)

16. A ‘chief financial officer’ is a person acting in a capacity in which that person has significant influence over the management and use of financial resources of the scheme and/or business decisions relating to the commercial activities of the scheme (if any)³.
17. We are more likely to be satisfied where an individual has:
    1. experience of developing and implementing financial strategies
    2. experience of managing the financial operations of a comparable or larger scheme or company
    3. experience of oversight of accounting and finance departments and compliance with accounting standards and practices
    4. experience of maintenance of financial records and flings
    5. knowledge and understanding of compliance with relevant laws and regulations

Competence of chief investment officer (multi-employer CDC schemes only)

18. A ‘chief investment officer’ is a person who has significant influence over the contents of the scheme’s investment strategy and/or the implementation, management, and communication of the scheme’s investment strategy (but does not have that influence because they provide investment services to the scheme)⁴. Investment strategy for this purpose means a document prepared by the trustees setting out the strategy for investing the assets that arise or derive from the payments made by or in respect of 
    members of the scheme.
19. Examples of significant influence might include:
    1. being a member (voting or not) of a trustee sub-committee
    2. being involved in a decision-making or advisory capacity in researching, selecting, and monitoring the scheme’s third party investment services providers (such as the trustees’ investment adviser, the scheme’s investment managers, custodians and similar)
    3. being involved in a decision-making or advisory capacity in researching, selecting, and monitoring investments for the scheme’s investment strategy
20. We are more likely to be satisfied where an individual:
    1. holds relevant investment qualifications, such as actuarial, CFA, CISI, and maintains any CPD requirements
    2. has relevant experience in developing and implementing investment strategies, and providing investment advice
    3. can demonstrate knowledge and understanding of investment trends and considerations
    4. has experience working with asset managers, platform providers, custodians, and other related entities in implementing and managing investments
    5. can demonstrate that they have relationships with appropriate asset managers and other investment service providers
    6. has experience of systems and processes appropriate for managing and monitoring investments
    7. has experience of communicating investments strategies
    8. has knowledge and understanding of compliance with investment laws and regulations

Legal references

¹ Paragraph 3(a) to (c) of Schedule 1 to the 2022 Regulations and Paragraph 3(a) to (c) of Schedule 1 to the 2025 Regulations

² Section 247 and section 248 of the Pensions Act 2004

³ Section 49(1) of the Pension Schemes Act 2021

⁴ Section 49(1) of the Pension Schemes Act 2021

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