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Continuity planning


Early draft of the code of practice

This code is not in force yet. It is an early version for the new code of practice consultation.

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You can also read more information about the consultation.

Published: 17 March 2021

Under section 249A of the Pensions Act 2004CO1 governing bodies of certain schemes must establish and operate an effective system of governance including internal controls (see Scheme governance). They should develop and implement continuity plans to ensure that the operations of their scheme can be maintained in the event of a disruption to the activities of the scheme. Our expectations for continuity planning are set out below.

Scheme managers of public service pension schemesCO2 do not have the same obligations in pensions legislation, but it is good practice for them to carry out continuity planning in the same way.

Governing bodies should:

  • seek to ensure continuity and regularity in the performance of the activities in the scheme
  • have a resilient business continuity plan (BCP) that sets out key actions in case of a range of events occur that impact the scheme’s operations
  • make sure member data and general scheme administration are included in the BCP
  • ensure advisers and service providers also have a BCP in place to maintain services to the scheme
  • choose how to rely on reports and information about their service providers’ BCP arrangements
  • set out roles and responsibilities within the plan, and agree these with service providers
  • regularly review process documents and maps, particularly after system or process change
  • prioritise scheme activities in the event of the BCP being triggered, for example pensioner payments, retirement processing and bereavement services
  • ensure continued access to resources, services and communications with key parties
  • have an awareness of the timeframes required to bring new resources on board
  • understand what contingency is in place to mitigate any under-resource due to, for example, increase in work volumes or the loss of staff
  • seek to identify any events which may reasonably occur that may require additional resources

Glossary and legal references

Governing bodies

Trustees or managers of an occupational pension scheme which is subject to the requirements under section 249A of the Pensions Act 2004

Internal controls

  • arrangements and procedures to be followed in the administration and management of the scheme
  • systems and arrangements for monitoring that administration and management, and
  • arrangements and procedures to be followed for the safe custody and security of the assets of the scheme. See Section 249A of the Pensions Act 2004.

Public service pension scheme

A scheme established under section 1 of the Public Service Pensions Act 2013

CO1Article 226A of The Pensions (Northern Ireland) Order 2005

CO2As defined in section 318(1) of the Pensions Act 2004
[Article 2(2) of The Pensions (Northern Ireland) Order 2005]