Contracting-out will cease in just seven months' time, on 6 April 2016. HMRC is providing a Scheme Reconciliation Service to enable schemes to reconcile their records against HMRC's records for all non-active members, a process that can be complex. In our experience some administrators have done this work under the terms of their existing agreement with the trustees, but trustees who are required to enter into a new agreement should watch out for liability caps, as well as ensuring the agreement deals adequately with data protection issues. HMRC's recent "Countdown Bulletins" have reminded schemes that they must register before 5 April 2016 if they wish to use the Scheme Reconciliation Service.
On 16 July the Government published the final form regulations, along with its consultation response, dealing with the rules that will apply to formerly contracted-out schemes from 6 April 2016 onwards. There has been no change to the basic policy that contracted-out rights accrued pre-6 April 2016 will continue to be subject to the same rules and restrictions after that date. However, there have been some changes to the detail of the regulations.