The Pensions Regulator’s new general code is here: What do trustees need to do now?

The Pensions Regulator’s new General Code, which consolidates the ten current codes of practice, is due to come into effect tomorrow, 28 March 2024.

The General Code, which was laid before parliament in January 2024, sets out the requirements that schemes need to meet in order to have an effective system of governance (“ESOG”) in place. Schemes with 100 or more members which are required to operate an ESOG need to carry out and document an Own Risk Assessment (“ORA”). My colleague, Rhanna Rankin, previously set out the key changes to the draft General Code first published in March 2021 in her January blog.

A reminder of trustee actions:

1. Review the General Code to understand what it contains and how it applies to your scheme.
2. Evaluate governance structure: compare the scheme’s governance structure with the expectations outlined in the General Code.
3. Review policies: understand existing policies, review dates and identify potential gaps.
4. Assess scheme against modules: evaluate the scheme against the modules in the General Code in relation to effective governance and internal controls.
5. Prepare for ORA: begin planning for the first ORA.

The pensions team at Burness Paull is ready to help you meet the requirements of the General Code. Our services include:

• providing training on the General Code;
• supporting trustees in carrying out a gap analysis with our General Code checklist;
• providing support to help trustees put in place a suitable governance framework; and
• reviewing scheme documentation, updating existing polices and drafting new policies to ensure compliance with the General Code.

If you would like to discuss how we can help, please contact us.