Record-keeping guidance for trustees and public service schemes | The Pensions Regulator Skip to main content

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Overview

As a pension trustee or someone running a public service scheme you are responsible for making sure the scheme has good records. This is still the case if you use a third-party administrator.

To manage a scheme properly you need to make sure it has accurate, complete and up-to-date records. You should have controls and processes in place to maintain these standards.

Failure to maintain complete and accurate records means you are at risk of not meeting your legal obligations. Poor record-keeping can have a huge impact on members and can be very expensive for your scheme if things go wrong due to bad or missing data.

Your role

You should review scheme data regularly. You or your administrator need to tell us about your data as part of your scheme return.

You need to work with your administrator to improve data where it isn’t good enough to run the scheme effectively.

You should not rely on the statutory audit to tell you the quality and accuracy of your data or the controls around it. You should take an active role in monitoring data. This should be an ongoing process.

You should discuss record-keeping at trustee meetings. This includes your standards, processes and any improvements you need to make. Although it can often be overlooked in favour of other priorities, good record-keeping is vital so that:

  • defined benefit schemes have accurate funding plans in place
  • defined contribution schemes can process core financial transactions promptly and accurately
  • all schemes can meet government and industry initiatives like the pensions dashboard

Types of records to keep

You need to keep records relating to:

  • your meetings and decisions
  • scheme documents including trust deed and rules, and any deeds of amendment or rule changes
  • member information – this includes common data and scheme-specific data
  • all contributions received
  • all other payments to and from the scheme
  • transfers of members’ benefits and related assets

You must keep records for at least six years. You’ll need to keep some for a much longer period.

Work well with the employer and administrator

Work with the employer to improve their record-keeping. You should help them understand their duty to provide accurate and timely information to the administrator.

You should work with the employer and administrator to investigate and fix any errors that you find.

Failing to meet record-keeping responsibilities

If you fail to meet your record-keeping responsibilities we will investigate. We may take enforcement action if you do not demonstrate adequate internal controls.

Report a breach of the law

Poor quality or missing data increases the risk of you being unable to meet your legal duties. If someone hasn’t complied with legislation relating to administration of a pension scheme this is a breach of the law.

You may need to report the breach to us. See our code on reporting breaches of the law.

2. What records to keep