In our March 2009 update, we noted that the Department for Work and Pensions (DWP) had published a consultation paper on the requirements for scheme disclosure of information to members, setting out its proposals for reform. The DWP’s response has now been published, together with proposed amendments to the disclosure requirements, which actually include fewer changes than anticipated.
The most notable proposed change which has been dropped, and which was included in the March 2009 paper, is the Government’s original intention to introduce a principles-based approach through the adoption of a “key overarching principle”. Proposals to replace the specified timescales in the current disclosure regulations with a requirement to disclose information within a “reasonable period” have also been dropped. However, the disclosure regulations will be amended to allow greater use of electronic communications. Members who do not wish to receive information electronically will be able to opt out.
The DWP intends to implement amending regulations on 1 October 2010, later than the originally proposed implementation date of 6 April 2010. The closing date for responses to the new consultation on the draft regulations is 1 March 2010.