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Scheme continuity planning

Code in force: 28 March 2024

This module forms part of our expectations for trustees of those schemes required to operate an effective system of governance, see Systems of governance.

  1. Under section 249A of the Pensions Act 20041, governing bodies of certain schemes must establish and operate an effective system of governance (see Systems of governance) including internal controls (see Internal controls). However, there are certain exemptions2. The system of governance must be proportionate to the size, nature, scale, and complexity of the activities of the scheme.
  2. Scheme managers of public service pension schemes3 do not have the same obligations in pensions legislation. This is therefore not part of our expectations on them, but it is good practice for them to consider carrying out continuity planning in the same way.
  3. Governing bodies should develop and implement continuity plans to ensure that their scheme operations can be maintained, in the event of a disruption to scheme activities. Additional resources on continuity planning are available online (The UK national standards body, BSI, maintains various resources for business continuity under ISO 22301).
  4. Governing bodies should:
    1. seek to ensure that the performance of scheme activities are continuous and regular
    2. have a resilient business continuity plan (BCP) that sets out key actions, in case of a range of events occurring that impact the scheme’s operations
    3. make sure key areas of scheme activities, including member data and general scheme administration, are included in the BCP
    4. ensure advisers and service providers also have a BCP in place to maintain services to the scheme
    5. choose how to rely on reports and information about their service providers’ BCP arrangements
    6. set out roles and responsibilities within the plan, and agree these with service providers
    7. regularly review process documents and maps, particularly after a system or process change and periodically test the BCP arrangements
    8. prioritise scheme activities in the event of the BCP being triggered, for example: receiving and monitoring contributions, pension payments, retirement processing, bereavement services, and minimising the risk of pension scams
    9. ensure continued access to resources, services, and communications with key parties
    10. have an awareness of the timeframes required to bring new resources on board
    11. understand what contingency is in place to mitigate any under resource due to, for example, increase in work volumes or the loss of staff
    12. identify any events which may reasonably occur that may require additional resources

Glossary and legal references

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.

Public service pension scheme

Schemes as defined in s318(1) of the Pensions Act 2004, established under section 1 of the Public Service Pensions Act 2013, new public body pension schemes and other statutory pension schemes which are connected to those schemes.

1 Articles 226A of The Pensions (Northern Ireland) Order 2005

2 Section 249A(3) of the Pensions Act 2004 (Article 226A (3) of The Pensions (Northern Ireland) Order 2005)

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