Most occupational pension schemes must provide a regular, usually annual, scheme return to The Pensions Regulator (TPR), containing prescribed information that, in part, depends on the type of scheme (DB, DC or Hybrid).
TPR typically issues a scheme return notice in December for DB schemes, and July for DC schemes.
Schemes must submit their forms using TPR’s online service, Exchange; trustees can access the online form only within the period during which they are obliged to complete it. Trustees must file a scheme return by the date stated on the notice. This will be at least 28 days after the date the notice was issued but, in practice, TPR aims to give six weeks to complete the scheme return. That said, it cannot offer any extension to the deadline.
The information required in a scheme return is summarised on the TPR’s website, together with a checklist showing any recent additions to the return.
If trustees fail to provide a scheme return, they may be liable for a civil penalty of up to £5,000 in the case of an individual and up to £50,000 in other cases.
- From 2018, scheme returns needed to include common and conditional (now known as ‘scheme-specific’) data scores. Common data is the basic information all schemes need to uniquely identify individual members. Scheme-specific data is member data that trustees require to enable them to administer their particular scheme.
- From 2019, trustees submitting DC returns will be asked to confirm when they last measured their scheme’s common data and scheme-specific data. This question has been included to allow TPR to track progress of schemes as they incorporate the record-keeping standards.
If TPR has concerns that its record-keeping standards are not being met, it may engage with individual schemes. If trustees fail to demonstrate they are taking “appropriate steps” to improve records, TPR may take action.
Data in the spotlight
So, in addition to other developments where quality of pension scheme data will be under the spotlight, such as pensions dashboards and addressing inequalities arising from Guaranteed Minimum Pensions, scheme returns are another example of why, when it comes to ‘dirty data’, there is increasingly no place to hide.