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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.


We’re currently reviewing the questions and the guidance for responding to the first Supervisory Return following feedback.

Any revision will not include requesting additional information beyond that already detailed. If you have any questions or need further information speak to your supervisor.

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?

Yes/No or N/A (if no significant event)

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 significant event requirements.

2.2 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.

3.1 Control functions – other (external auditors, assurance providers)

Please provide an update on any events or activities which may occur as part of ongoing monitoring of the effectiveness and maintenance of your scheme’s systems, processes and governance unless you have already provided this as part of your ongoing interactions with us.

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.

To answer this question, we would like you to provide us with information where events or activities have occurred which relate to the ongoing monitoring of key service provision, scheme administration and investment governance.

If any of the following events or activities have occurred in the last 12 months, provide us with available documentation to demonstrate how this activity was discussed and resolved by the trustee board:

  • service provider review (including advisers)
  • consideration of advice on the ongoing suitability of the design of the default option(s) or broader investment offering (ie the addition of new investment options)
  • changes to the risk profile or costs and charges related to investments
  • IT or data security breaches affecting either the scheme or key service providers
  • disaster recovery events affecting either the scheme or key service providers
  • administration issues which were brought to the attention of the trustees (only where these are not considered a significant event)
  • trustee board effectiveness reviews
  • reviews and updates to any key scheme documentation (in particular, key policies or process documents which were referenced as evidence in your systems and processes questionnaire)
  • updates to your communications strategy or member communications

Where any of these events or activities have occurred, provide us with the following documentation:

  • section of the trustee meeting minutes where this issue was discussed, any actions arising and details of who they are allocated to, along with any deadlines set
  • any advice, reports or other meeting papers provided to the trustees related to this event or activity

Also, ensure that these events are reflected on your risk register and trustee annual business schedule or plan.

You may be expected to provide (or have already provided) more detailed information and/or evidence related to trustee governance, service provision and other matters related to systems and processes depending on the level of intensity of supervision. Where this is the case, your supervisor will provide clarity on any of the above which would create duplication of information and, therefore, would not be expected in your supervisory return.

4.1 Member/employer investments

Has there been any change or are there any planned changes to the scheme's investment arrangements during the last review period that haven't been reported to us through the significant event regime?


If yes, provide further details of the change, applicable date and rationale. Attach supporting documents/evidence, eg new or amended detailed fund guidelines for default funds and multi-asset funds.


5.1 Financial sustainability

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

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 (including your costs and liquidity plan within it or as a separate document), highlighting and explaining key changes since the previous business plan was sent.

If there have been no changes since a recently submitted business plan there is no need to submit this again but please provide a clear explanation of why you have not submitted one. Note that our general expectation is that schemes will need to revise their business plan each year (see paragraph 322 of Code of Practice 15).

7.1 General

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


8.1 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