Coronavirus (COVID-19)—the pensions implications for trustees
Coronavirus (COVID-19)—the pensions implications for trustees

The following Pensions practice note provides comprehensive and up to date legal information covering:

  • Coronavirus (COVID-19)—the pensions implications for trustees
  • TPR’s position
  • The PPF’s position
  • The Pensions Ombudsman’s position
  • The FCA’s position
  • HMRC’s position
  • Joint statements and guidance
  • Issues relating to trustee meetings
  • Running the scheme
  • Contingency planning and continuity
  • More...

Coronavirus (COVID-19) represents a big challenge for trustees running pension schemes.

This Practice Note describes the position taken by the different pensions regulatory bodies (including the Pensions Regulator (TPR) and the Pension Protection Fund (PPF)), as well as the various issues trustees of pension schemes may encounter.

This Practice Note also describes the impact of coronavirus on public service pension schemes (including through the Coronavirus Act 2020).

TPR’s position

TPR has repeatedly expressed a willingness to regulate pragmatically and sympathetically during the coronavirus crisis. For instance, TPR will take a practical approach to the late reporting of breaches caused by coronavirus issues, provided that they are reported to TPR within three months of the breach.

TPR went as far as to grant certain easements, some of which expired on 30 June 2020 (eg the ability to suspend DB transfer activity, delays in submitting revised recovery plans) and others it extended until 30 September 2020 (eg flexibility on the pension consultation requirements applicable on a reduction in employer contributions for furloughed workers).

TPR has set out its position in a series of guidance documents, some of which it has updated over time:

Date (Last update)TitleKey pointsComments
12 March 2020COVID-19: What pension schemes need to consider (now withdrawn)This was TPR’s first statement on coronavirus. This short statement focused mainly on issues relating to

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