Last week, the Pensions Regulator updated its Covid-19 guidance on reporting duties and enforcement activity.

The updated guidance confirms that, with effect from 1 January 2021, the Regulator is asking pension providers and trustees of defined contribution (DC) schemes to revert to reporting payment failures that are 90 days outstanding, rather than after 150 days. This will become mandatory from 1 April 2021.

The updated guidance has caused some confusion as it is unclear whether it is optional for pension providers and trustees to report payment failures that are oustanding for 90 days, between January and April, or whether the Regulator requires them to do this. We hope that this will be clarified in due course.

In the absence of any further clarification it would be safest for providers and trustees to resume reporting late payments after 90 days from 1 January unless their is a clear justification for not doing so.

In addition, from 1 October 2020, the Regulator has confirmed that it will:

  • revert to reviewing all DC Chair’s statements submitted on or after that date (unless the Regulator specifically notifies a scheme otherwise), and
  • resume enforcing the requirement for schemes to submit audited accounts and to review their statement of investment principles, as usual.


Tim Smith
Tim Smith
Professional Support Lawyer, London
+44 20 7466 2542
Francesca Falsini
Francesca Falsini
Paralegal, London









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