The new year has already seen progress made on a number of key initiatives, including The Pensions Regulator’s (TPR) long-awaited new General Code of Practice, which was published earlier this month.

In addition to this, the Department for Work and Pensions (DWP) has shared the final funding regulations for UK defined benefit (DB) pension schemes, which are set to come into force from April 2024.

However, whilst the industry now has the final regulations in hand, it is still awaiting the final DB Funding Code from TPR, with recent delays prompting concern that some schemes will not have much time to meet the new requirements.

"Schemes will need to ensure their scheme is compliant when the new requirements are in force – schemes with valuation effective dates around autumn 2024 may not have much time," Gateley Legal pensions partner, Michael Collins, stated.

This may not be the only guidance trustees need to get to grips with, as Collins suggested that we also may see the TPR revised employer covenant guidance that was expected in 2023.

"Under the new scheme funding regime the existing four covenant gradings will move to an assessment of financial ability and contingent asset support based upon the legal definition of employer covenant strength contained in the draft funding and investment strategy regulations," he explained.

Work to extend auto-enrolment (AE) has also rolled over from last year, with a consultation on plans to extend AE to lower earners and younger workers to be introduced "when parliamentary time allows".

In addition to this, Collins pointed out that the government is set to review the climate risk governance and reporting requirements that currently apply to larger occupational pension schemes and decide whether it wishes to extend the requirements to other schemes.

The removal of the lifetime allowance (LTA) also remains an important consideration for the industry, as Collins noted that scheme administration processes will need to be adjusted and schemes will need to assess the impact of the revised tax regime on their rules.

Indeed, Sackers partner, Lucy Dunbar, recently warned that the timetable for the latest pensions tax changes is "extremely tight", meaning trustees and their administrators will need to get to grips with a number of key issues to stay on track.

Cyber considerations are also set to be a key consideration in 2024, as Squire Patton Boggs head of pensions practice, Matthew Giles, argued that "it is essential that cyber security is top of trustee agendas in the wake of the cyber-attack on Capita and also in recognition of the increased risk that comes with the rollout of artificial intelligence across the industry".

Further reforms could lie ahead, however, and trustees will need to be mindful of any further developments to the Autumn Statement pension reforms.

In particular, Collins said that further updates are expected on the plans to ease DB surplus access, permitting 100 per cent Pension Protection Fund (PPF) coverage for DB schemes that pay an increased levy, and the possibility of a PPF-operated public consolidator.

In addition to this, there could be further updates on plans for a trustee register, the development of a new defined contribution (DC) value for money framework, and progress on the small DC pots default consolidator model.

However, Sackers managing partner, Helen Ball, emphasised the need for pension scheme trustees to get on with "business as usual", and avoid getting overly distracted by any of the changes that may, or may not, be coming down the track.

She stated: "In 2024 the biggest challenge we will all face is to remain focused on what matters now to pension savers.

"There is a lot of “noise” at the moment about new policy initiatives that could bring changes for all of us – things such as tax changes, illiquid investments, market consolidation, new retirement choices, and new duties for trustees.

"That could take up a lot of airtime at meetings and a lot of brain power if we start over-thinking the potential consequences.

"But meanwhile, we’ve still got to make sure the “business as usual” work is carried out to a high standard and is well resourced, so that the pensions eco-system keeps functioning well and doesn’t get bogged down too much in philosophical debates about the future.

"The priority, whether you are an employer, trustee, provider, administrator or adviser, is to make sure people have access to a good value pension scheme that is well run and administered, and that will provide a sound home for their savings – whatever kind of scheme or product you are offering."

Indeed, broader industry experts previously argued that action is needed in 2024, with concerns that important initiatives could fall to the wayside, particularly in an election year.

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