Relevant pension scheme trustees have been urged start considering what changes will be needed to comply with The Pensions Regulator's (TPR) consolidated Code of Practice and begin planning a process for implementing these changes.

In a blog post, 20-20 Trustees stated that smaller schemes could find the new requirement for the establishing of an effective system of governance particularly “burdensome”.

The post noted that the requirements will be a lot for the trustees of all schemes to consider, regardless of their make-up, but noted that smaller schemes that still have over the minimum threshold of 100 members could struggle in particular.

2020 Trustees trustee director, Kate Leigh, wrote: “We are well versed in working with small schemes and fully appreciate that when it comes to pensions, size doesn’t matter – the challenges facing smaller scheme can be just as complex as those facing larger ones. This is essentially reflected in the code which requires all schemes, regardless of size, to have first-rate governance.”

Additionally, the blog post noted that the requirement for schemes to conduct an own risk assessment could be taxing for trustees, noting that TPR itself had acknowledged that conducting this would be a “significant piece of work” and arguing that the level of data required could be “formidable” for the lay trustee.

Leigh commented: “Certainly, the experience of 20-20 Trustees as we speak to clients and colleagues in the sector appears to suggest that whilst many are aware of the new code, there seems to be little appreciation of just what is around the corner and the scale of the work schemes will need to do in order to be fully compliant.

“We are encouraging schemes to think about who is going to be taking the lead on this – trustee boards or professional advisers. It is important the terms effective system of governance and own risk assessment are on the agenda now as further resources and additional skills may well be necessary.”

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