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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.

  Question area  Question details Guidance for completion
1.0  Supervisory Return Completion

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
  • scheme name
  • PSR
 1.1 Supervisory Return Completion 

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 unticked.

By ticking this box, I confirm that I am authorised to indicate on behalf of the trustees/managers of the scheme, and/or others receiving notices, notifications and other documents on their behalf, their willingness to receive notices, notifications and other documents electronically from The Pensions Regulator (TPR) regulator at the email address that I have entered/confirmed for them.

2.0  Significant Events   

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

Y/N or N/A (if no SE).

If no, read the significant events guidance and use the reporting template.

A penalty under section 10 of the Pensions Act 1995 may apply to any person who has failed to comply with the SE requirements.
2.1  Fitness and propriety 

Please explain the due diligence you have undertaken to ensure that all persons subject to a fit and proper assessment under section 7 of the Pension Schemes Act 2017 remain fit & proper both individually & collectively. This explanation should also contain how you have continued to assess the collective competence of the trustee and scheme strategist.

Provide an explanation of 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. 

3.0  Systems and processes. Trustee oversight. 

Please provide evidence of the Trustee Oversight of how the Scheme continues to meet the authorisation criterion for systems and processes.

In particular,  if any of the following events or activities have occurred in the last 12 months, please summarise what has occurred explaining how this activity was discussed and resolved by the Trustee Board:

  1. Service provider review (including advisers)
  2. Consideration of advice on the ongoing suitability of the design of the default option(s) or broader investment offering (i.e. the addition of new investment options)
  3. Changes to the risk profile or costs and charges related to investments
  4. IT or data security breaches affecting either the scheme or key service providers
  5. Disaster Recovery events affecting either the Scheme or key service providers
  6. Trustee Board Effectiveness reviews
  7. Updates to your communications strategy or member communications 

We would like you to provide us with information where the listed events or activities have occurred in the last 12 months.

- To respond to this point you may wish to list each of the events we have detailed, explain if they have occurred and how this was discussed and addressed by the Trustee Board (i.e. it was raised at meeting XX with the following action points taken away). We may then seek supporting information where appropriate. 

- Your response may rely on the Master Trust Assurance Framework (TECH 05/20 AAF) and possibly be supported by the Internal controls of service organisations AAF (TECH 01/20). If you have provided these within the past 12 months then you do not need to resubmit this but instead you may refer to them in your response. Your answer should detail when this was reviewed by the Trustee Board and what the results of this review were. 

- We do not expect full details and documents of all the events - rather summaries of what has occurred.


- You should also ensure that these events are reflected (if appropriate) on your risk register and trustee annual business schedule or plan. We expect you to use your judgement about whether something belongs on these records. Where something is not included, you may wish to explain why in your response to this question to avoid confusion. During normal Supervision we will be collecting copies of these documents throughout the year.

- 'updates to your communications strategy or member communications' should include anything discussed by or presented to the trustee board but not captured in the SE framework. The level of detail provided is for the Trustee Board to decide and we expect responses to vary.

- If you have submitted any documentation in relation to these points within the past 12 months simply reference this submission in your response. 

3.1  Systems and Processes. Process updates.  Please explain how the systems and processes described to us at authorisation have been maintained. 

The intention is to establish that the key policies or process documents which were referenced as evidence in your systems and processes questionnaire are correctly reviewed and updated in line with your approach to version control.

Attestation to this effect will be sufficient (i.e. listing the key process documents provided and attesting that they have been reviewed and updated by the relevant parties).  We may then ask to review specific process documents, especially if an issue arises in relation to that process and it has been amended since it was submitted for the authorisation process. 

Given the existence of Significant Event K we do not expect you to resubmit the S&P questionnaire, however, in some cases we may request additional information.  

4.0  Business Plan  Provide a copy of your most up to date 3-5 year Business Plan (including your CALP within it or as a separate document) and an updated Scheme financial details template. Where this has been submitted within the last 12 months you need not submit it again. 

Section 9(3) of the Pensions Scheme Act 2017 (the Act) states; The Scheme Strategist must review the Business Plan at least once a year and revise it as appropriate. 

Section 9(6b) of the Act states; The Scheme Strategist or the Trustees must provide the Pensions Regulator with the most recent Business Plan, and any supporting information or documents required by the Regulator within three months of the plan being revised.

Because of the nature of the information it contains, we anticipate that most master trusts will have to revise their Business Plan at least once a  year and we expect to be provided with Business Plans promptly. 

Expected revisions may include; replacing forecast numbers (revenue, costs, assets under management, membership) for Financial Year 1 with actuals, updating subsequent years to reflect the amended opening positions, and adding another year to the Business Plan. 

To ensure prompt submission expected revisions should be completed within an annual cycle – this will allow three months for signoff processes and submission to TPR. Should there be delays to this process you will need to update your Supervisor and discuss expected dates of submission.

Accordingly, TPR would expect to receive an updated Business Plan at least annually.  Any material changes to the Business Plan outside of the annual review, must be communicated to us as a Significant Event. In such situations, Schemes are required to notify us within 5 working days of any changes that require revision of the Business Plan.

Where a Business Plan has been revised, this must be sent to TPR within 3 months of the revision. The new or revised Business Plan will be reviewed and assessed by TPR, with a view to establishing whether the Master Trust continues to meet the authorisation criteria.

At the time of providing a revised Business Plan, a Master Trust must provide any supporting documentation or documents requested by TPR. However, we would expect the following documents to be provided:

  1. A summary of all of the changes / revisions to the previous Business Plan, including clear referencing to page / paragraph numbers. 
  2. A Scheme Financial Template (see guidance for completing this)
  3. If the Scheme’s financial reserves have been increased as a result of the revision, evidence to demonstrate funds are in place.
  4. An updated Costs, Assets and Liquidity Plan (CALP) 
5.0  Continuity Strategy 

Has there been any change to your Continuity Strategy since it was last submitted to TPR?


If yes, provide the revised version of the Continuity Strategy, highlighting and explaining any changes. 

Section 12(7) of the Act states; A scheme strategist must keep the continuity strategy under review and revise it if appropriate.

TPR expects to be provided with a revised Continuity Strategy which is fully aligned with any revisions made to the Business Plan i.e. a revision to the calculated scheme financial reserves.  An updated Continuity Strategy should be submitted with a revised Business Plan and in any event, within three months of any revision in accordance.

The new or revised Continuity Strategy will be reviewed and assessed by TPR, with a view to establishing whether the Master Trust continues to meet, the authorisation criteria.  At the time of providing the revised Continuity Strategy we would expect to be provided with a summary of the changes / revisions to the previous Continuity Strategy including clear referencing to page / paragraph numbers. 

6.0  Material Developments  Are there any other material issues or developments (past or planned) affecting the Master Trust that you would like to report to TPR?  This is an opportunity to highlight material issues or developments that have not been discussed with your Supervisor. 
7.0  Supervisory Return Declaration 

Declaration that:

  • they 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  


If you do not understand how a question should be answered by your scheme then speak to your supervisor. There is significant variety within the master trust market and so we expect responses to vary. The questions are often directed at ensuring all schemes provide key information but many will have provided this outside of the Supervisory Return process. This may mean you have a limited submission to make.

You should provide any new audit assurance framework (AAF) reports (including master trust assurance and reports provided by third-party administrators) when they become available. However, if these have not been provided within the current scheme year they can form part of your supervisory return.