Guide to assessment of the fit and proper persons requirement

About this guide

This guide explains how applicants should approach the fit and proper persons requirement as part of their authorisation application for a multi-employer collective defined contribution (CDC) scheme. It sets out:

• how applicants notify us of all the individuals they have identified as acting in one or more of the capacities subject to the fit and proper assessment
• the information required by us to undertake a fit and proper assessment, this will determine whether a person meets the fit and proper criteria to act in that capacity

You should read this guide alongside the fitness and propriety section in our CDC code of practice. This sets out when we are more likely to be satisfied that all relevant persons involved in the multi-employer CDC scheme are fit and proper. 

Relevant persons include: 

• the person who establishes the scheme 
• the trustees 
• those who can appoint or remove the trustees 
• those who can amend or vary the trust deed or scheme rules
• the scheme proprietor
• any person who promotes or markets the scheme
• the chief financial officer
• the chief investment officer

Where any of the above capacities are performed by a company or partnership, we must assess each individual who is exercising a management or executive role within that company or partnership. 

We may also assess:

• Whether a person who exercises a 'core function' in relation to a multi-employer CDC  scheme is fit and proper to act in such a capacity. A 'core function' includes a strategic, executive or management role carried out on behalf of a person acting in one or more of the above capacities.
• Any individuals who have significant control over the scheme proprietor.

You should also refer to our guidance on identifying persons for the fit and proper assessment.

Published: 31 July 2026

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Forms

The following forms must be submitted to us as part of your authorisation application or, in the case of an authorised multi-employer CDC scheme, before an individual takes up their role in relation to a scheme. 

Fit and proper role identification form (completed by the applicant)

Use this form to tell us about: 

• all individuals, companies, and partnerships acting in one or more of the capacities subject to the fit and proper assessment (you should refer to our guide to identifying persons for the fit and proper assessment)
• all individuals who are exercising a management or executive role within a company or partnership that is acting in one or more capacities subject to the fit and proper assessment 
• all individuals who exercise a core function on behalf of a person acting in one or more of the capacities 
• all individuals who have significant control of the scheme proprietor
• all persons connected with any of the individuals identified for the fit and proper assessment who have the ability to influence the scheme’s design or operation through this connection  

Note: We will not fully assess the fitness and propriety of connected persons. However, we may look at matters relating to them when assessing the fitness and propriety of the person to whom they are connected.

Evidence should be provided by the applicant to demonstrate the collective competence of the whole trustee board, and those comprising of the scheme proprietor company, chief financial officer, and chief investment officer, plus those who promote or market the scheme. This should align with the applicant’s submission under systems and processes, including in relation to trustee governance.

Individual fit and proper form (completed by individuals)

All individuals subject to the fit and proper assessment (apart from those exercising core functions or with significant control of the scheme proprietor) must complete this form as part of the authorisation application to show us how they satisfy us that they are fit and proper because they meet the requirements for honesty, integrity, financial soundness, and good conduct. See the Fitness and propriety: Honesty, integrity and financial soundness and Fitness and propriety: Conduct of individuals involved with the scheme modules of the CDC code for more information.

In addition, the trustees, scheme proprietor, chief financial officer, chief investment officer, and those who promote or market the scheme must show us that they possess the relevant knowledge, skills, professional competence, expertise, and experience to act in those capacities competently. See the Fitness and propriety: Assessment of competence module of the CDC code more information.

We will decide if we want to conduct any fit and proper checks for those exercising core functions or with significant control of the scheme proprietor. This will form part of your pre-application engagement with your supervisor. Following this engagement, unless we direct you otherwise, we do not require this form to be completed as part of your authorisation application by those exercising core functions or with significant control of the scheme proprietor. We do however expect you to consider and assess which of your teams fall under these definitions. 

Multiple roles

Where an individual acts in one or more capacities subject to the fit and proper assessment across any combination of more than one single employer CDC scheme, connected employer CDC scheme, multi-employer CDC scheme, or different sections of a CDC scheme, they will need to list their associations with each scheme and sections of a scheme in their individual fit and proper form. The same form can be linked to different applications. 

Separation of functions 

The Pension Schemes Act 2021 directs that certain capacities in relation to a multi-employer CDC scheme may not be undertaken by a trustee of the scheme, or any member of the trustee board. This is to help ensure that appropriate standards of governance and oversight are maintained, that potential conflicts of interest are limited, and ultimately, that decisions taken on behalf of the members are taken in their interests alone and free from commercially influenced pressures.

A trustee of a scheme is not permitted to:

• be the scheme proprietor
• promote or market the scheme
• act as chief financial officer of the scheme

Although they are unable to act in these capacities, we expect trustees to maintain their usual standards of knowledge and understanding of these capacities and provide appropriate challenge to those performing them.

Certificates

Criminal conviction certificate

All individuals who have been identified as being subject to the fit and proper assessment must submit a criminal conviction certificate together with their Individual fit and proper form: 

• A basic disclosure criminal conviction certificate must be submitted if the individual lives in the UK and has not spent more than six months in a foreign country within the last year. The issue date on the certificate must not be older than six months before the date of its submission to us. Further information on how to obtain a UK basic criminal conviction certificate.
• We can accept a colour photo or colour scan of a basic level criminal conviction certificate. Note that if you are using the online DBS update service you will need to generate and provide a one-time access code as providing a copy of your online certificate is not valid. See guidance provided by the Disclosure and Barring Service.
• If, in the last five years, the individual has spent more than a six-month period continuously in an individual foreign country, they should also enclose the relevant jurisdictional criminal conviction certificate equivalent for each relevant country. The issue date on the certificate must not be older than six months before the date of its submission to us. The disclosure must be at a federal level. The original document should be provided, but a colour copy can be provided if it is certified as a true copy by a person acting as a public notary or equivalent sworn affidavit. It must be accompanied by an official translation, if not in English, and notarised. See Home Office guidance on criminal record checks for overseas applicants for more information on which countries provide a non-UK equivalent and under which circumstances. 

Certificate of good standing

Where an individual who has been identified as being subject to the fit and proper assessment is accredited, approved or authorised by a professional and/or regulatory body, they should submit, together with their Individual fit and proper form a scanned copy of a certificate of good standing or equivalent written confirmation (letter) from the appropriate professional body/regulator. This should state that the individual is:

• authorised by, or a certified member of, that professional body/regulator
• entitled to practise (if relevant)
• not subject to any condition or other restriction, and
• not subject to disciplinary proceedings

The issue date of the certificate or written confirmation must be dated within three months before the date of its submission to us. It must be accompanied by an official translation, if not in English, and notarised. 

Individuals who are authorised by the Prudential Regulation Authority (PRA), Financial Conduct Authority (FCA) or Solicitors Regulation Authority (SRA) or members of the Pensions Management Institute (PMI) do not need to include a certificate of good standing or equivalent written confirmation, although they should specify on their form whether they are authorised by any of those regulatory/professional bodies.

Demonstrating honesty, integrity, financial soundness, and good conduct

Applicable to: All roles being assessed as fit and proper
Relevant forms: Individual fit and proper form

The individual fit and proper form contains a list of questions in relation to honesty, integrity, financial soundness and conduct. 

Individuals should answer all questions honestly and openly and include all relevant information. If an individual is unsure whether to disclose a particular matter, they should disclose it with any additional information that they feel is relevant. 

We will assess all relevant information including any matters disclosed, taking into account:

• their relevance to the capacity being assessed
• the impact 
• how long ago they occurred

In some cases, these matters may mean that an individual is automatically barred under legislation from acting in certain capacities. For example, we are very unlikely to be satisfied that a person can be a trustee if they are currently bankrupt.  

We may also consider other matters we consider appropriate, including whether there are any persons connected to those we are assessing that are relevant to our assessment of fitness and propriety.

Individuals should explain the circumstances of any matters they disclose, or of any matters we consider relevant, including any steps taken to resolve or address them, and any other mitigating factors relevant to a fit and proper assessment.  

Demonstrating knowledge, skills, professional competency, expertise, and experience (competence)

Applicable to: All roles being assessed as fit and proper
Relevant form: Individual fit and proper form and role identification form 

Each individual must provide a statement in the individual fit and proper form setting out how they possess the relevant knowledge, skills, professional competency, and experience appropriate for their role.

We need to be satisfied that there is sufficient knowledge, skills, expertise, and experience shared collectively by: 

• the individuals on the trustee board 
• those comprising the scheme proprietor company
• those comprising the chief financial officer 
• those comprising the chief investment officer
• those who promote or market the scheme

This information should be set out in a statement in the role identification form, explaining how the knowledge and skills of the trustee board and the professional competence, expertise and experience of the other four capacities are appropriate for the multi-employer CDC scheme. Supporting documentary evidence, for example a skills matrix, should be provided to support the information in the form.

Demonstrating competence is not a one-off event. We expect all those involved in running a multi-employer CDC scheme to understand their duties and responsibilities. There should be clear plans for developing and maintaining knowledge, skills, professional competency, expertise, and experience over time.

The vetting process

We will conduct a two-stage vetting process to cover the following aspects:  

• honesty, integrity, financial soundness and good conduct   
• competency  

We will begin with assessing honesty, integrity, financial soundness and good conduct. The individual will need to provide a criminal conviction certificate and, where relevant, a certificate of good standing. We will conduct our own searches and liaise with external agencies in order to complete the vetting process. In the second stage, we will look at competency. 
 
We may make enquiries and verify and supplement the information provided in the individual fit and proper forms with third parties; for example, a credit reference check, if relevant to the role. 
 
We will seek to highlight any major issues as early as possible, with both the individual and the multi-employer CDC scheme. However, our assessment of an individual’s honesty, integrity, financial soundness, good conduct, and competency will have dependencies with other aspects of the assessment process. We will formally respond once the assessment of all the other areas (for example, financial sustainability and systems and processes) have been completed. 
 
The current process will only be undertaken for the purpose set out in this guide.

Individual trustees

To satisfy us that they are competent, all individual trustees must demonstrate that they have attained the required level of knowledge and understanding at the time of assessment and on an ongoing basis. Trustee knowledge and understanding is defined in the Pensions Act 2004 and broadly means that trustees must attain a working knowledge of the documents governing their scheme, for example the trust deed and rules. They should also have knowledge and understanding of pensions and trust law as applicable, and the principles of investments. See the general code of practice for more information on trustee knowledge and understanding. 

Knowledge and understanding

Trustees can demonstrate they have undertaken training to a basic level of knowledge by completing the Trustee Toolkit, which covers the key areas of scheme governance and administration.

If trustees have not completed the Trustee Toolkit, they must demonstrate that they have completed an equivalent learning programme or gained equivalent experience.  

Examples of equivalent learning activities may include, but are not limited to: 

• formal training and assessment, for example from the PMI or the Pensions and Lifetime Savings Association (PLSA)
• a certificate in trusteeship
• pensions and financial qualifications

Note: The formal training and assessment mentioned above are examples only, and we do not endorse any particular services.

We expect all trustees to receive training on multi-employer CDC scheme-specific matters, including on understanding their scheme’s design and what is being offered to members, as well as the key tasks in running the scheme. We expect trustees to be able to evidence that this training has been received as part of the fit and proper assessment process.

Qualifications and accreditation

Evidence should be provided by the applicant to demonstrate the qualifications, accreditation, knowledge and experience of all relevant persons (as identified by the trustee). This may include trustees, the chief financial officer, chief investment officer, individuals involved in the promotion or marketing of the scheme, and any other person whose role may be relevant to our assessment.

We may also assess any person who undertakes a core function. A core function is a strategic, executive or management role carried out in relation to, or on behalf of, a person whom we are required to assess under the fit and proper persons requirement.

Applicants should demonstrate that the individuals identified possess the qualifications, skills, knowledge and practical experience necessary to perform their roles effectively within a multi-employer CDC scheme environment. Professional qualifications and accreditations may provide evidence of competence, but they will be considered alongside broader evidence of experience, judgement, decision-making and successful performance in relevant roles.

When assessing competence and experience, we are interested not only in what an individual has studied or achieved through formal accreditation, but also how they have applied that knowledge in practice. Applicants should therefore be able to demonstrate how an individual's experience has equipped them to perform the responsibilities associated with their role and to address the challenges likely to arise within the operation of a CDC scheme.

Applicants should also demonstrate how relevant persons maintain and develop their knowledge on an ongoing basis. This should include an explanation of how learning needs are identified, how development activities are selected, and how learning is applied within the individual's role.

We are likely to place greater weight on development activities that are planned, role-specific and aligned to identified knowledge or skills gaps than on isolated or ad hoc learning activity. Evidence should demonstrate that learning and development activities form part of a considered approach to maintaining competence and supporting effective scheme governance.

Qualifications and accreditation

• Individuals should possess qualifications appropriate to the role they perform.
• How any professional qualifications, accreditations or memberships support the responsibilities of the role.
• Individuals have sufficient technical knowledge, practical experience and professional judgement to perform the role effectively.
• Qualifications and accreditation are supplemented by relevant experience and evidence of successful application in practice.
• Individuals have the skills and expertise necessary to discharge their responsibilities and contribute to the effective operation and governance of the scheme.

Ongoing learning and development

Competence is not a one-off assessment at appointment and should be maintained throughout an individual's involvement with the scheme. All individuals must demonstrate that they have attained the required level of knowledge and understanding at the time of assessment. However, they should also continue to evaluate, maintain and develop their skills throughout their appointment to ensure they remain capable of meeting the evolving needs of the scheme. 

We expect individuals to explain within the individual fit and proper form:

• how they periodically assess their own knowledge and skills
• how any knowledge or skills gaps are identified
• what actions are taken to address those gaps
• how learning and development activity is prioritised and monitored
• how learning is applied to support the performance of their role

Individuals should keep their knowledge current and in line with developments in legislation, regulation, governance standards, investment practices, member communications and scheme operations.

We expect learning and development arrangements to be proportionate to the complexity of the role being performed. In particular, individuals occupying senior, specialist or decision-making positions should be able to demonstrate a depth of knowledge and a commitment to ongoing development that is consistent with those responsibilities.

Individuals should be able to demonstrate not only that learning has taken place, but also how it has improved their understanding, enhanced their capability and informed their contribution to the scheme.

Practical evidence applicants could provide

• relevant professional qualifications and certificates
• professional body memberships
• current accreditation status
• CPD records and learning logs, documented learning and development plans and completed training records
• attendance at industry events, seminars and regulatory briefings
• evidence of role-specific learning relating to CDC schemes, pensions, investments, actuarial matters, communications, governance or risk management
• examples of how learning has been applied in practice
• evidence of experience gained in comparable roles or environments
• assessments, performance reviews or other documentation demonstrating development of knowledge and capability

Professional trustees and specialist roles

Trustees must specify the title of any qualification or accreditation, the awarding body and the date it was attained, together with an explanation of how the qualification contributes to meeting the knowledge and understanding requirements relevant to their role.

Professional trustees and individuals appointed because they bring specialist expertise, for example actuarial, investment, legal, financial, communications or administrative expertise, should be able to demonstrate an enhanced level of competence and experience in those fields.

We expect professional trustees to have obtained and maintained sufficient knowledge, skills and experience through their professional trustee activities. Professional trustees should ordinarily hold accreditation through the Association of Professional Pension Trustees (APPT) Accreditation Framework, the Pensions Management Institute (PMI) Professional Trustee Accreditation programme, or another recognised accreditation programme of comparable standing.

Importantly, accreditation should be supported by evidence of practical application, sound judgement and continuing professional development relevant to the responsibilities undertaken within the scheme.

Collective competence

The role identification form must contain a statement, together with supporting evidence, setting out how, collectively, each of the following capacities possess the appropriate balance of knowledge, skills, professional competence, expertise and experience appropriate for their scheme and how these are monitored and maintained to run the scheme effectively:

• trustees
• the scheme proprietor
• the chief financial officer 
• the chief investment officer
• those who promote and market the scheme

The role identification form and CDC code detail the areas that must be demonstrated for each capacity and some key markers where we will be more likely to be satisfied that collective competency has been demonstrated.

Promoters and marketers

It is possible that the structure for those promoting and marketing the multi-employer CDC scheme will be more complex than other capacities that require an assessment of collective competence. There may be several separate third-party contracts in place covering different aspects of managing and approving promotion and marketing activity. For example, there could be a third party working exclusively on digital marketing campaigns, whilst one or more other third parties could be working on sector specific campaigns, whilst another party may be operating a general employer acquisition campaign. 

It is important that full consideration is given to identify all those who are either managing or approving campaigns. Consideration should also be given to identifying those with both a management role or executive role in promoting and marketing the multi-employer CDC scheme. These individuals will need to be identified on the role identification form. Additionally, where one or more of those parties is a company or partnership, details should be provided on the role identification form.

How to submit the Individual fit and proper form, together with any supporting evidence, to us 

Individuals should submit their completed forms, together with any supporting information, by following the instructions provided by their named contact. We will not be able to begin our assessment of your scheme’s authorisation application until all individuals who are subject to fit and proper assessment have submitted an ‘Individual fit and proper form’ together with any supporting information.

Please see our Privacy notice for information on how we process and gather personal data submitted to us.

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