Disclosure requirements

The 2013 Disclosure Regulations

With effect from 6 April 2014, the Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013, SI 2013/2734 (the 2013 Disclosure Regulations) consolidated the disclosure requirements previously contained in:

  1. the Occupational Pension Schemes (Disclosure of Information) Regulations 1996, SI 1996/1655, and

  2. the Personal Pension Schemes (Disclosure of Information) Regulations 1987, SI 1987/1110

into a single set of regulations which prescribe the information requirements applicable to trustees or managers of occupational pension schemes and personal pension schemes.

With effect from the same date, the two above regulations were consequently repealed.

For information on the disclosure requirements applicable to occupational and personal pension schemes before 6 April 2014, see:

  1. Practice Note: Occupational pension schemes—disclosure requirements before 6 April 2014 [Archived]

  2. Practice Note: Personal pension schemes—disclosure requirements before 6 April 2014 [Archived]

  3. Practice Note: Winding up an occupational pension scheme—statutory disclosure before 6 April 2014, reporting and record-keeping requirements [Archived]

  4. Checklist: Disclosure of information to scheme members before 6 April 2014—checklist [Archived]

  5. Checklist: Basic scheme information before 6 April 2014—checklist [Archived]

Key changes made by the

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DWP to evaluate pension scheme climate disclosure regime as part of government’s modernisation of climate disclosure and transition planning in UK financial markets

As part of its efforts to modernise the UK’s sustainability reporting framework, the government has introduced three consultations intended to “unlock billions in clean energy investment”. In doing so, the government is consulting on how to implement its manifesto commitment to mandate UK-regulated financial institutions (including banks, asset managers, pension funds and insurers),  as well as FTSE 100 companies,  to develop and implement credible transition plans that align with the 1.5C goal of the Paris Agreement. The government sees transition planning as a vital part of its commitment to secure the UK’s position as the green finance capital of the world. Notably, one consultation from the Department for Energy Security and Net Zero, seeks views on how the government should implement this commitment by ensuring an orderly transition aligned with global climate goals, aiming to enhance transparency to facilitate efficient capital allocation, enabling companies to seize opportunities from the global net zero transition, and bolstering the growth and international competitiveness of the UK’s financial services industry.  In particular, the consultation from the Department for Energy Security and Net Zero indicates that during 2025, the Department for Work and Pensions (DWP) will conduct a review of the Occupational Pension Schemes (Climate Change, Governance and Reporting) Regulations 2021, SI 2021/839, utilising evidence provided by the Pensions Regulator (TPR). The DWP regards this review as a logical starting point to assess the effects of the current climate disclosure regime (put in place following the recommendations from the Taskforce on Climate-Related Financial Disclosures (TCFD)) and to consider future steps for climate change reporting. In parallel with the TCFD review, the DWP has tasked TPR with evaluating the feasibility of transition plans within pension schemes. Accordingly, TPR is organising an industry working group, including key stakeholders and major occupational pension schemes, and is set to deliver its findings to the DWP later in 2025.

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