Trustees must register with HMRC by 5 April 2016 to be able to request data from HMRC with which to reconcile scheme records. This is where schemes provide guaranteed minimum pension, or 'GMP', rights in relation to pre April 1997 contracted out service.

Trustees are under a duty to reconcile scheme GMPs with HMRC’s records, and the process of reconciliation may well reveal members with incorrectly attributed rights and / or who have received under- or overpayments.