Deadlines are approaching for new investment compliance and disclosure requirements. Pension trustees should check that they are on track to meet the deadlines.

The deadline for some of the requirements is 1 October 2020.

In particular, there are requirements to include "implementation statements" in annual reports completed on or after 1 October 2020. Trustees who complete their annual report before that date will not need to produce them until next year.


The following requirements apply to both DB and DC schemes1.

What is affected?

What's changing?

What's the deadline?

Statement of Investment Principles (SIP) – content

The SIP needs to set out the trustees' policy in relation to the arrangement they have with their asset managers.

"Arrangement" is not defined but could include contractual agreements and less formal monitoring procedures which the trustees follow.

More specifically, the SIP needs to address (or explain why it does not address) the following areas:

how the arrangement incentivises the asset manager to align its investment strategy and decisions with the trustees' other investment policies, including policies on "financially material considerations" such as environmental, social and governance issues.

how the arrangement incentivises the asset manager to make decisions based on assessments about medium to long-term financial and non-financial performance of an issuer of debt or equity and to engage with issuers of debt or equity in order to improve their performance in the medium to long-term.

how the method (and time horizon) of the evaluation of the asset manager's performance and the remuneration for asset management services are in line with the trustees' other investment policies.

how the trustees monitor portfolio turnover costs incurred by the asset manager, and how they define and monitor targeted portfolio turnover or turnover range; and

the duration of the arrangement with the asset manager.

1 October 2020

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1 Some exemptions apply to schemes with less than 100 members.

Originally published 28 July 2020

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