• Migration nears for HMRC’s Managing Pension Schemes
• Investment Association issues updated executive pensions guidance
• Contribution Notice Code of Practice comes into force

Migration nears for HMRC’s Managing Pension Schemes

HMRC’s latest newsletter alerts pension scheme administrators to the need to migrate the schemes they administer from HMRC’s current system (Pension Schemes Online) to its successor (Managing Pension Schemes).

It also provides some of the necessary detail to achieve this transfer, points to guidance to enrol on the new system for administrators that have yet to do this, what to do if an administrator or practitioner currently holds multiple scheme IDs, how to manage and operate access to the new system, and to keep details up to date.  An Appendix to the newsletter adds further detail.

However, it won’t be until at least Spring 2022 before administrators will be able to start the migration, with the actual date to be confirmed in a future newsletter.  And, in order for the migration to operate, certain information needs to be provided.

Comment

The relationship between the scheme administrator and practitioner is mentioned very lightly in this newsletter – ie the authority provided by the scheme administrator (through their account on the current system) to allow the practitioner (on the current system) access to the scheme and the ability of the latter to submit reports etc.

If the scheme administrator which provided access to the practitioner does not enrol on the new system then that relationship is not automatically recreated under the new system, with the result that the practitioner will not have access until authority is provided by another scheme administrator enrolled on the new system or, it appears, until such time as the original scheme administrator enrols.

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Investment Association issues updated executive pensions guidance

In its latest pay guidelines the Investment Association says that ensuring the alignment of executive pensions with the wider workforce (when expressed as a percentage of pay) will continue to be a priority for investment managers.  It notes, in its separate letter sent to FTSE 350 companies, that over 90% of FTSE 100 companies analysed have already met its expectations.

To support its desire for pensions to be aligned by 2022 the Association will “red top”:

• Any new remuneration policy that does not explicitly state that any appointed executive director will have their pension contribution set in line with the majority of the workforce
• Any remuneration report where executive pension contributions are not aligned to the majority of the workforce rate or there is not a credible action plan to align pension contributions for incumbent directors by the end of 2022

Red topping is the Association’s highest level of warning and is applied to those companies for which investors should have the most significant and serious corporate governance concerns.

Comment

The pensions aspects of this year’s guidance is broadly consistent with that issued last year (see Pensions Bulletin 2020/47), but reflecting the now closeness of the end of 2022 alignment date.

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Contribution Notice Code of Practice comes into force

Code of Practice 12, setting out the circumstances in which the Pensions Regulator may use its expanded Contribution Notice powers, has come into force, after being presented to Parliament and waiting for the requisite time.  The Code is unchanged from the finalised draft published on 28 September 2021 (see Pensions Bulletin 2021/40) and has not been recast into the new “single code” format that was promised at the time.

Regulations were laid before Parliament on 23 November, bringing the Code into force on 25 November 2021.

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