In our previous briefing, we commented on new obligations being imposed on trustees by the Occupational Pension Schemes (Investment and Disclosure) (Amendment) Regulations 2019 (the 2019 Regulations). These regulations build upon regulations published in 2018 - the Pension Protection Fund (Pensionable Service) and Occupational Pension Schemes (Investment and Disclosure) (Amendment and Modification) Regulations 2018 (the 2018 Regulations). This briefing summarises the key new obligations arising from both sets of regulations.

New Obligations

The table below sets out the key requirements being introduced as a result of both the 2018 Regulations and 2019 Regulations. Many of these relate to the Statement of Investment Principles (SIP). Please speak to your usual Stephenson Harwood pensions law contact to understand how these obligations may apply to your scheme. In certain circumstances, exemptions may apply. 


The deadline for the first round of changes is imminent. Trustees should therefore ensure that they fully understand which new obligations apply to them and undertake the necessary groundwork to ensure compliance by the relevant deadline.