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Supervisory return questions for master trusts

The questions you will need to answer and documents you will need to provide when you complete a supervisory return for a master trust.

Supervisory return questions Guidance for completing the supervisory return

1.1 Supervisory return contact details

Please provide details of the person we should contact if there are questions about this supervisory return.

  • title
  • name
  • role
  • company name
  • address
  • telephone
  • email

1.2 Consent to electronic service

We would like to deliver documents by email wherever possible. If you consent to this, please tick the box. If you do not consent, leave the box un-ticked.

By ticking this box, I confirm that I am authorised to indicate on behalf of the trustees/managers of the scheme, and any other recipients, that they are willing to receive notices and other documents from The Pensions Regulator (TPR), at the email address I have specified for them.


2.1 Scheme governance and management

Have all significant events been reported to TPR over the previous 12 months?

Y/N or N/A (if no significant event)

A penalty under section 10 of the Pensions Act 1995 may apply to any person who has failed to comply with the significant event requirements.

2.2 Scheme governance and management

Is the scheme an ear-marked scheme as defined in regulation 1(2) of the Occupational Pension Schemes (Requirement to obtain Audited Accounts and a Statement from the Auditor) Regulations 1996?


If ‘Yes’, please request the following from your auditor:

  • The most recent accounts published in relation to each insurance company with which the trustees or managers of the scheme hold policies of insurance or annuity contracts falling within the description in that definition.
  • Where any such insurance company is part of a group in respect of which there is a duty to prepare group accounts under section 399 of the Companies Act(c), the most recently published accounts.

2.3 Scheme governance and management

Please explain the due diligence you have conducted within the last 12 months to ensure that all individuals subject to a fit and proper assessment under section 7 of the Pension Schemes Act 2017 remain fit and proper, both individually and collectively.

This explanation should also state how you have continued to assess the collective competence of the trustees and scheme strategists.

Explain any instances where an individual has not remained fit and proper, and what action has been taken to address this.

Describe the activities to monitor the ongoing fitness and propriety of individuals, as well as how the collective competence of trustee board and strategist has been maintained. This may include the following:

  • Any checks the scheme has conducted on the individuals.
  • Any review that has been conducted on the trustees’ knowledge and understanding.
  • Any training that has been undertaken by the trustees and strategists.

Please note these lists are indicative, not exhaustive.

We would expect this narrative to align with Schedule 4, paragraph 5 set out in the Occupational Pension Schemes (Master Trusts) Regulations 2018.

Schedule 4, para 5. Whether there are systems and processes:

b) for determining and recording that persons involved in the scheme in the capacities listed in section 7(2) and (3) of the Act (fit and proper persons requirements) are, and remain, fit and proper

c) for monitoring and recording trustees’ learning and development, and for ensuring that it is appropriate to the scheme’s activities.

Your narrative should be formally reviewed and signed by the trustees as this is a declaration which relates to the effectiveness of the trustee board’s ongoing oversight of the scheme.

2.4 Scheme governance and management

Provide a copy of your most recent trustee annual business schedule or plan. This is the document outlining the schedule of trustee activities for the current scheme year and completed activities from the prior scheme year.

The schedule or plan should make it clear if an item/event has been completed and the date when this happened. If items/events have not been completed, we would expect to see this reflected in the plan along with a revised date for completion highlighted.

Some schedules/plans do not currently note when items are completed. If this is the case, or there are completed activities from the previous scheme year where it is unclear from the schedule/plan whether they have been completed, please also provide an accompanying narrative which lists completed activities and the date on which they were completed.

3.1 Control functions – risk management and compliance

Please provide the most up to date copy of your risk register, highlighting any changes since your last submission, such as:

  • closed risks/issues
  • new risks/issues
  • changes to action plans/dates which are driven by the risk register
  • any refinement of the scope of a particular risk
  • changes to the mitigating controls or monitoring of a particular risk
  • changes to the rating of a particular risk

You will need to provide an updated version of the risk register that has been reviewed and signed off by the trustee board. You can provide a decision log or minute extract to evidence this sign-off.

To accompany this, please provide a narrative summary of work undertaken by trustees and the scheme strategist over the previous year to identify, manage and mitigate risk.

As with expectation 2.4, if there are activities that have been closed, added or changed and would not be obviously present in your standard risk register framework, you will need to submit an accompanying narrative listing these activities, including any commentary on how and why they were closed or changed.

3.2 Control Functions – Other (external auditors, assurance providers)

Please provide an update on how you have monitored effective functionality and maintenance of your systems and processes.

If available, please provide a copy of your most recent Audit Assurance Framework (AAF), or equivalent report summarising and signposting the key issues identified.

To answer this question, you do not need to fill in the full systems and processes questionnaire again. As the supervisory return is an annual submission we are not looking for the same level of detail as the authorisation process. We want to understand how the trustees have remained comfortable that the functionality of the master trust’s systems and processes are monitored effectively and maintained both in the preceding 12 months and over time in the following areas:

  • Scheme administration.
  • Processing of core financial transactions.
  • Record-keeping.
  • IT security, managing cyber risk and business continuity and/or disaster recovery.
  • The quality of advisers and advice.
  • The quality of member communications and how the trustee board has reacted to any member feedback.

You should prepare a brief summary signposting relevant sections, paragraphs and/or pages of any additional evidence documents referenced in the narrative. The narrative should cover any updates or changes to the systems and processes listed above, since your last submission to us/your authorisation application. If there has been a significant change in processes or the advisers who feed into these processes, please highlight this. If you have referenced a documented process in your narrative, this will also need to be submitted.

Please provide any new AAF 01/06, 02/07 or equivalent independent external assurance (IXA) reports, summarising and signposting any key issues identified. This includes assurance reports relating to the scheme, the provider and/or the administrator. If you have not received a new AAF/IXA since your scheme has become authorised, you do not need to send the existing report again but please highlight in your response when your next report is due to be signed off and sent to us.

If you are providing your supervisory return shortly after being authorised, please broadly explain your plan for keeping your assurance up to date in the future.

4.1 Member/employer complaints

  • Please provide the following information:
  • The number of complaints received and information on the cause
  • Please describe your complaints resolution process.
  • What metrics do you gather about complaints?
  • Number of complaints not resolved within eight weeks.
  • Percentage of complaints upheld or rejected and any action taken.
  • Details of any complaints referred to the Pensions Ombudsman Service (POS)including:
    • percentage referred to the POS
    • percentage upheld or rejected by the POS
    • the total redress value paid in relation to POS decisions
  • What analysis is produced based on complaints metrics/how do you assess complaint trends?
  • Can you provide any examples of where a complaint has led to a change of process?
  • What complaint information is shared with the trustees?

The Systems and Processes questionnaire that you completed as part of your authorisation application included code requirement 15g – “There are processes in place for escalation of issues or complaints to the relevant decision-maker and to resolve the root cause of the issue”. This requirement ensures that you have a process in place. We are requesting more in-depth information as part of the supervisory return to ensure that your systems and processes are working and that the governance around them is effective and based on relevant complaint metrics/information.

Please provide a narrative that specifically responds to our questions but also provides any further detail you feel it would be useful for us to know in relation to complaints. We are interested in your methodology for defining, resolving and identifying trends with complaints.

5.1 Financial sustainability

Please complete the scheme financial details template.

Scheme financial details template.

Guidance on completing the template.

We expect the trustee board to formally review and sign off the scheme financials template before it is submitted as part of your supervisory return.

5.2 Capital/liquidity management and funding

Please provide a copy of your latest scheme funder cashflow forecast.

This question only applies to scheme funders with a section 10(3) exemption.

6.1 Business plan (financial viability)

Provide a copy of your most up-to-date three-to-five-year business plan if this has not already been submitted.

If we already have your most up-to-date business plan, please do the following:

  1. Provide us with the last date of review of your business plan.
  2. If it was submitted, please confirm the date on which receipt was acknowledged by TPR.
  3. If it was not submitted, please submit (including your costs and liquidity plan (CALP) within it or as a separate document), highlighting and explaining key changes since the previous business plan was sent to us.

7.1 Continuity strategy

Has there been any change to your continuity strategy since it was last submitted to us?


If yes, provide the revised version of the continuity strategy, highlighting and explaining any changes.

If we already have your most up-to-date continuity strategy, please do the following:

  1. Provide us with the last date of review of your continuity strategy.
  2. If it was submitted, please confirm the date we acknowledged receipt.
  3. If it was not submitted, please submit the strategy along with this return.

8.1 General

Are there any other material issues or developments (past or planned) affecting the master trust that you would like to report to us?


9.1 General

Please declare that:

  • you are authorised to submit the supervisory return
  • the scheme trustees/manager are aware of the information supplied on this form
  • the information supplied on this form is true and correct