Pensions - Key legal issues guide

Winter 2017

Last updated: 2 January 2018 Note: This summary is intended to be a general guide only and it is not a substitute for legal advice.

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This document summarises key current and future legal issues that trustees and employers should be aware of in relation to their pension schemes. If you think any of these issues may be relevant to your scheme, we recommend you speak to your usual Eversheds Sutherland adviser.

This document is divided into the following sections:

| Current issues - key issues where action may be needed within the next three months

| On the horizon - key issues where action may be needed within the next three to twelve months

| General housekeeping - key issues that need regular/ongoing consideration

| Other issues of general interest

For a shorter summary of current issues that UK pension schemes and sponsors should be aware of, see our latest UK Pensions Agenda.

For an overview of current issues affecting pension schemes and sponsors across Europe, see our latest European Pensions Agenda.

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Contents

Current issues – where action may be needed within the next three months .............. 1

PPF levy 2018/19 .................................................................................. 2

Protected rights rules............................................................................. 3

Changes to money laundering rules ......................................................... 3

New data protection rules ...................................................................... 4

Auto-enrolment contribution increases ..................................................... 4

DC benefits with guaranteed element ...................................................... 5

DC member borne commission ............................................................... 5

DC costs and charges ............................................................................ 6

Money purchase annual allowance ........................................................... 6

Death benefits for same sex spouses and civil partners .............................. 7

Excepted group life assurance schemes ................................................... 7

On the horizon – where action may be needed within the next three to twelve months 8

Guide to the Chair’s statement ................................................................ 9

Cyber security ...................................................................................... 9

Brexit and pensions ............................................................................. 10

General housekeeping issues requiring regular review/consideration ....................... 11

VAT on scheme costs ........................................................................... 12

Regulator governance campaigns .......................................................... 12

Pension liberation scams - developments ............................................... 13

Equalisation - GMPs ............................................................................. 14

Trustee knowledge and understanding (TKU) .......................................... 15

Other issues of interest ..................................................................................... 16

Safeway equalisation case .................................................................... 17

Investment consultants – competition referral ........................................ 17

Pensions Regulator intervention ............................................................ 17

Auto-enrolment review ........................................................................ 18

Master trusts ...................................................................................... 18

Pension increases ................................................................................ 19

DB White Paper ................................................................................... 19

Current issues – where action may be needed within the next three months

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue Timing/action

PPF levy 2018/19 The PPF published its final levy rules for 2018/19 in December 2017. Most of the proposals in the PPF’s

consultation last spring have been adopted. Some of the key points are listed below.

■ The levy estimate is £550m, about 10% less than the previous year’s estimate.

■ The existing ten levy band structure will be maintained and changes to the Experian scorecard model

(including the use of credit ratings and an industry specific model for financial institutions) will proceed

broadly as proposed.

■ The deficit reduction contribution certification system will be simplified.

■ A “guarantor strength report” will need to be prepared by a professional adviser before certification of Type A

contingent assets (group company guarantee) that are expected to result in a levy reduction of £100,000 or

more. The report will need to demonstrate that the guarantor could meet the guarantee in the event of the

insolvency of the employer. Trustees will be expected to complete a report with each re-certification. This is

predicted to affect one in five guarantees.

■ Changes will be made to contingent asset documentation, with new standard forms due to be published in

mid-January. These new forms will need to be used for new contingent assets entered into after publication.

■ Some existing Type A (group company guarantee) and Type B (security over cash, real estate or securities)

contingent assets will need to be re-executed on a new standard form before the next (2019/20) levy year.

The PPF has now clarified that this applies only to those which include a fixed cap on the amount guaranteed

(ie not those limited only by reference to section 179 or section 75 liabilities). This should reduce significantly

the number of contingent assets requiring re-execution.

■ The deadlines for providing information to the PPF have been published and can be viewed at the end of its

policy statement. Note that the key deadline for the provision of much information is Saturday, 31 March

2018, which is over the Easter weekend.

DB schemes should now

start planning their levy

reduction measures.

Note in particular the new

requirement to obtain a

guarantor strength report

in respect of Type A

guarantees involving a

levy saving of £100,000

or more. If required,

covenant advisers should

be engaged as soon as

possible.

Type A and B documents

with a fixed cap will need

to be re-executed (most

likely by end of March

2019). This will require

significant advance

planning.

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue Timing/action

Protected rights rules

Where a scheme was contracted-out on a money purchase basis before 6 April 2012, its rules will have contained

provisions for protected rights (money purchase benefits provided in place of the state second pension). In some

cases, rules may have been drafted in such a way that the abolition of protected rights did not automatically mean

that the scheme ceased to have to make any special provision in relation to them. To deal with this, trustees were

given a statutory power to modify rules by resolution to remove protected rights provisions. This power falls away

if not exercised before 6 April 2018.

Schemes previously

contracted out on a

money purchase basis

should check whether a

resolution to remove

protected rights provisions

has been passed. If not,

consider whether one is

required before 6 April

2018.

Changes to money laundering rules

During summer 2017, the Government issued new money laundering regulations aimed at preventing money

obtained as a result of criminal activities from appearing to come from legitimate sources.

The regulations contain obligations that apply to trusts in general and, as such, are relevant to pension scheme

trustees. The record keeping requirements that apply to trustees under these regulations are already in force.

And, while not relevant to most trustees, those who pay certain types of taxes will also need to register with

HMRC’s new Trusts Registration Service, in some cases as early as January 2018 – see updated HMRC guidance

here. Additional obligations also apply to professional trustees.

Compliance should not be too onerous. However, action is required immediately.

For more information, please click here and here.

Trustees must start

keeping money laundering

records immediately. They

should decide urgently

whether they need to

register with HMRC.

Professional trustees

should also be aware of

their additional money

laundering obligations.

Money laundering

compliance should be

added to scheme risk

registers.

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue Timing/action

New data protection rules

The European General Data Protection Regulation (GDPR) will come into force on 25 May 2018. There is not

much time left to plan and take action to meet its new requirements.

Trustees and sponsors will have material new obligations in relation to personal data they hold and members will

need to be given additional information. Appropriate internal policies must be put in place and agreements with

third parties who handle data will need to be reviewed and most likely updated. In general, trustees will also

need to have registered as a data controller with the Information Commissioner’s Office. Significant fines may be

levied for non-compliance.

For more information, please click here.

GDPR compliance plans

should now be well

advanced. Trustees and

employers who have not

yet done so should put in

place an action plan

urgently.

Auto-enrolment contribution increases

The transitional period for total minimum AE contributions of 2% (with at least 1% from the employer) expires on

5 April 2018 (previously, this was scheduled for 30 September 2017).

The next transitional period (with total contributions of 5% and employer contributions of 2%) expires on 5 April

2019 (previously, this was scheduled for 30 September 2018).

Check what members

were told in relation to

minimum contributions

and when they would

increase. If rules hard-

code the old phasing

dates, members may need

to be consulted (and rules

amended) if revised dates

are used. Note that there

may also be complexity

around payroll systems /

pro-rating increases for

the first month.

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue Timing/action

DC benefits with guaranteed element

Where members flexibly access or transfer DB benefits or so-called “safeguarded flexible benefits” (DC benefits

that have a guaranteed element) they must take independent advice if the value of their benefits exceeds

£30,000. Changes are being made to the way safeguarded flexible benefits are valued for these purposes. The

amendments take effect from 6 April 2018 but transitional provisions have applied since 1 October 2017.

From 6 April 2018, there is also a new requirement to give members with safeguarded flexible benefits (of any

value) who ask about transferring or converting them personalised risk warnings explaining the guarantee and

what it is worth, together with projections. In some cases it may not be straightforward to assess whether

benefits are covered by the new requirements or not.

For more information, please click here.

Consider whether there

are any DC benefits in

your scheme with a

guaranteed element that

could be covered by the

new requirements.

Consider how to

communicate to

members.

DC member borne commission

Member borne commission has been banned since 6 April 2016 for new contracts set up by occupational schemes

that are qualifying schemes for auto-enrolment purposes and include money purchase benefits.

From 1 April 2018, the ban is extended so that service providers must also comply with it for contracts entered

into before 6 April 2016.

Trustees should expect to

receive written

confirmation from

providers that they are

complying with the ban.

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue Timing/action

DC costs and charges

Trustees of most schemes providing money purchase benefits are required to report on scheme transaction costs

in the Chair’s statement (within seven months of the end of each scheme year).

From 3 January 2018, the FCA’s conduct of business sourcebook is amended so that fund managers are under a

duty to give information on transaction costs on request to schemes that invest directly or indirectly in their funds.

Separately, in December 2017, the DWP concluded its consultation on the disclosure of costs, charges and

investments in DC occupational schemes. This proposes that:

■ the Chair’s statement is extended to include more detail on costs and charges, including an illustration of their

compounding effect

■ costs and charges information is made available on the internet, and

■ schemes must disclose to members, on request, the “top level” pooled funds in which the members have

been invested in the previous scheme year.

A consultation response is currently awaited and changes are expected to come into effect from 6 April 2018. The

FCA is planning to consult on similar rules for workplace personal pension schemes during 2018.

Trustee should ensure

they have received

information on transaction

costs for the Chair’s

statement.

Start planning for these

disclosure changes. Watch

out for the final

regulations and ensure

that any new

requirements are met by

the expected “in force”

date of 6 April 2018.

Money purchase annual allowance

The money purchase annual allowance (MPAA) is triggered where an individual has flexibly accessed money

purchase benefits from any arrangement (by taking their benefits as a lump sum or through flexi-access

drawdown) and limits the annual amount that members can subsequently accrue in any money purchase

arrangement.

The MPAA was due to be reduced from £10,000 to £4,000 on 6 April 2017. However, the relevant legislative

provisions were dropped at the last minute before the Finance Act 2017 was finalised. The Government now

reinstated this change effective from 6 April 2017 via the Finance (No.2) Act 2017.

Consider member

communication and

whether “scheme pays”

will be available to meet

tax charges arising.

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue Timing/action

Death benefits for same sex spouses and civil partners

In July 2017, the Supreme Court handed down its judgment in Walker v Innospec Ltd and others. This case looks

at a defined benefit scheme where the survivor’s pension payable to a surviving civil partner or same sex spouse

is restricted so that it reflects only the member's pensionable service since 5 December 2005, the date on which

the Civil Partnership Act 2004 came into force. The Supreme Court overturned the previous Court of Appeal

decision and held that this restriction is unlawful.

The precise implications for schemes that apply the December 2005 exemption will need to be considered

carefully. Affected schemes will most likely need to change their benefit structures in respect of surviving civil

partners and same sex spouses going forward, as well as facing the prospect of retrospectively re-calculating

benefits already paid.

We understand the Government is currently considering what, if any, action to take in relation to same sex

partner pension benefits following this case. It is not clear what is being contemplated or what the Government’s

timescales are.

For more information on this case, please click here.

The first step is for

trustees and employers to

check the rules of their

schemes to identify

whether they have to date

applied the statutory

exemption on same sex

survivor benefits.

Schemes that have

applied the exemption will

need to take advice on

their position and are

likely to have to take

steps to remove it.

Excepted group life assurance schemes

Employers with staff affected by previous reductions in the lifetime allowance could consider setting up an

excepted group life assurance scheme to provide death benefits. For more information, please click here.

However, note that the Finance Act 2017 removes some of the income tax and NICs advantages of offering an

excepted group life scheme via a salary sacrifice/flexible benefit arrangement.

Employers offering an

excepted group life

scheme via salary

sacrifice/flex should

consider the impact of the

Finance Act 2017

immediately.

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On the horizon – where action may be needed within the next three to twelve months

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue Timing/action

Guide to the Chair’s statement

In November 2017, the Regulator published a new “quick guide” to the Chair’s statement, which is designed to be

read alongside its DC code of practice and accompanying “how to” guides.

The guide sets out the legal requirements in relation to the Chair’s statement (which most occupational pension

schemes providing money purchase benefits are required to prepare within seven months of the end of each

scheme year) and the Regulator’s expectations as to how trustees should meet them. It also includes a checklist

on what the statement needs to include to be legally compliant. Much of the content reflects what the regulations

require but in some areas the Regulator appears to have particularly high expectations.

Trustees of schemes with

money purchase benefits

should be aware of this

guide.

Cyber security The Pensions Regulator is urging trustees to ensure they (and their administrators) have suitable cyber security

strategies in place. This should include measures to protect against cyber crime and attacks that could disrupt

scheme activities.

Trustees should

understand the risks

posed by cyber attacks,

and ensure that suitable

measures are put in place

to protect schemes.

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue Timing/action

Brexit and pensions It currently appears that the UK will leave the EU by the end of March 2019. Although it will be some time before

the terms of the UK’s future relationship with the EU are known, there are things that schemes and employers can

consider and plan for now, and changes they can start to make, to help protect their interests.

In the short term, Brexit is unlikely to have a significant effect on the legal and regulatory framework for UK

pension schemes. However, in the longer term, it could open the door for UK legislation to deviate from EU

requirements in some respects.

Meanwhile, the new IORP Directive will introduce new governance and disclosure requirements for occupational

pension schemes in the EU. It will also relax the funding requirements for cross-border schemes and introduce

greater member protection on cross-border transfers. Technically, this needs to be implemented into UK law by

mid-January 2019. However, as the deadline is so close to the UK’s expected exit from the EU, it is currently

unclear to what extent the UK Government will implement it. For more information on the new IORP Directive,

please click here.

For more details on the pensions implications of Brexit, please see our Speedbrief here and the Regulator’s

statement here. We will keep you updated on developments relating to pensions and to other areas of law via our

Brexit hub.

Trustees’ and employers’

main immediate concerns

will be around funding,

investment and covenant.

Further thought will need

to be given to other action

points as matters develop.

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General housekeeping issues requiring regular review/consideration

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue Timing/action

VAT on scheme costs Two European Court of Justice cases (Case C-26/12 PPG Holdings BV and Case C-464/12 ATP Pension Service

A/S) looked at the VAT position in relation to management and administration costs of DB and DC occupational

schemes respectively. As a result, HMRC reviewed its policy and extended the current 70:30 split approach

outlined in HMRC Notice 700/17 until 31 December 2017.

HMRC has now updated its VAT manual to say that that the current 70:30 approach may be maintained for the

time being, with an option for schemes and employers to use alternative approaches (such as VAT grouping or

tripartite contracts) where they consider that these may be more appropriate.

For noting.

Regulator governance campaigns

The Regulator carried out two surveys looking at compliance with its DB funding code and DC governance code.

It says that the results of both are disappointing in relation to small and medium sized schemes and highlight

major gaps in the standards expected by the Regulator. In particular it highlights the following failings:

■ they tend to display poorer governance standards, for instance they place less focus on training

arrangements, regular board assessments, effective internal controls and oversight of third parties

■ many small and medium DC schemes, (including those used for automatic enrolment) are not meeting

standards around administration (eg ensuring prompt and accurate transactions), investments (setting

appropriate investment strategy for the default fund) and value for members (assessing quality of services

provided to members), and

■ significant issues also remain among DB schemes, in particular around integrated risk management and fair

treatment of the scheme.

The Regulator’s 21st century trusteeship campaign aims to drive up the standards of governance across pension

schemes. The programme includes a series of communications to make clear what the Regulator’s expectations

are of those responsible for managing a scheme effectively. The Regulator intends to build on this resource in

the coming months.

Trustees should consider

regularly the extent to

which their scheme is

meeting the standards

expected by the

Regulator.

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue Timing/action

Pension liberation scams - developments

The Government consultation on pension scams looked at whether changes should be made to existing

legislation to limit the statutory right to transfer to some occupational schemes. It also considered a ban on cold

calling and restrictions on which companies can apply to register a scheme. For more information on the scams

consultation, click here.

The response to this consultation was published in August 2017 and set out the intended next steps which

include:

■ a cold calling ban in relation to pensions

■ limiting the statutory right to transfer so that it covers only FCA approved personal pension schemes,

authorised master trusts and transfers where a genuine employment link to the receiving occupational

pension scheme can be evidenced, and

■ tightening HMRC rules to prevent the opening of fraudulent pension schemes.

Many details remain to be ironed out. These include considering how legitimate transfers to QROPS can be

catered for. Apart from measures to make it harder to open scam schemes (in respect of which legislation has

now been published), the Government did not set out a firm timetable for these changes.

However, there has been pressure, including from the Work and Pensions Committee, to ban cold calling

urgently and the Government has now indicated that it plans to bring forward draft legislation in early 2018.

Trustees and

administrators should

keep transfer processes

under review and await

further developments.

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue Timing/action

Equalisation - GMPs Since the European Court of Justice case of Barber v GRE was decided on 17 May 1990, pension schemes have

had to provide benefits on an equalised basis. It has long been unclear whether, and if so how, inequalities

caused by GMPs accrued between May 1990 and April 1997 should be equalised.

In November 2016, the Government issued a proposed methodology for equalising for the effect of GMPs. This

methodology was developed after extensive engagement with the industry and proposes a one-off calculation of

whether a male or female member would be better off following conversion of the better benefit to non-GMP

benefits. Existing conversion legislation would be amended to facilitate this. The Government responded to the

consultation in March 2017 and confirmed that it intends to go ahead with its proposals – it does not feel that

they will be affected by Brexit as equal treatment obligations are already enshrined in UK law.

However, a legal claim in relation to GMP equalisation was issued against Lloyds Bank in 2017. The Government

may revisit its proposals depending on the outcome of that case, which is expected to be heard by the High

Court during 2018.

Our Speedbrief on the Government’s proposals is here.

Monitor developments.

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue Timing/action

Trustee knowledge and understanding (TKU)

Under the Pensions Act 2004, trustees are required to have knowledge and understanding of the:

■ law relating to pensions and trusts, and

■ principles relating to scheme funding and investment.

The Pensions Regulator’s TKU code of practice emphasises the need for trustees to read their scheme

documentation thoroughly. Trustees are also expected to complete the Regulator’s online trustee toolkit.

The Regulator’s discussion paper on 21st century trusteeship and DC Code of Practice also emphasise the need

for trustees to have a training and development plan in place.

Trustees should undertake regular training to keep up to date. In addition, trustees of DC schemes are now

required to describe in their annual governance statement how they have met the TKU requirements during the

scheme year and how the combined knowledge and understanding of the trustees (and the advice available to

them) enables them to properly exercise their functions.

Our introductory training courses, “Introduction to DB pensions” and “Introduction to DC pensions”, are intended

to help trustees meet this statutory requirement. We also offer bespoke training and run regular complimentary

pension breakfast briefings.

If you would like to find out more about our pensions training, please ask your usual Eversheds Sutherland

adviser.

Assess your training

needs and attend relevant

training.

DC trustees must be

prepared to report on how

they have met their TKU

requirement each year in

their annual Chair’s

governance statement.

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Other issues of interest

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue

Safeway equalisation case

It had been understood that where a scheme attempted to equalise by an announcement, subsequently confirmed by deed, the deed

could not be backdated to the date of the announcement as this would amount to retrospective equalisation which was not permitted

under European law.

The Court of Appeal has now cast doubt on that view in Safeway v Newton and will refer the question of retrospective deeds of

amendment where the rules specifically allowed the effective date of a deed to be the date of an earlier announcement to the Court of

Justice of the European Union. It may take some years for this issue to be heard. However, in the meantime, if a similar situation is

identified it should no longer be assumed that equalisation could not be effective from the date of an announcement where later

confirmed by a deed (in line with the rules).

Investment consultants – competition referral

Following a decision by the Financial Conduct Authority in September 2017, the Competition and Markets Authority (CMA) launched a

market investigation into the supply and acquisition of investment consultancy and fiduciary management services to institutional

investors and employers.

The CMA is carrying out hearings and roundtables with interested parties as well as a survey focusing specifically on trustees. It will

publish a report containing provisional findings (and, if it finds that there is an adverse effect on competition, provisional remedies) and

plans to conclude the investigation by March 2019.

We identified some of the key issues arising from previous stages of this process together with suggested actions here.

Pensions Regulator intervention

A noticeable theme during 2017 was the Pensions Regulator becoming more interventionist in relation to DB scheme valuations. In

particular it:

■ is committed to intervening in more valuation cases than in the past

■ where it does get involved, it is doing so in a more interventionist, rigorous and proactive manner than before, with much less

tolerance for late valuations, and

■ is willing to consider escalating action more quickly and exercising the full range of its powers – including those which have never

been used in the past. This includes its powers under section 231 of the Pensions Act 2004 to determine valuation assumptions in

the event of a “failure to agree” by the parties.

For more information, please click here.

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue

Auto-enrolment review

In December 2017, the Government published its review of automatic enrolment. It concludes that auto-enrolment is working and it

plans to build on its success. The key proposals, to be implemented by the mid-2020s are:

■ the lower age limit for auto-enrolment will be reduced from 22 to 18

■ pension contributions will be calculated from the first pound earned, rather than from the lower earnings limit, currently £5,876

■ the “entitled workers” category will be removed

■ those earning at or below £10,000 will not be automatically enrolled - however if they opt in they will also benefit from pension

contributions on 8% of all their earnings

■ the trigger for auto-enrolment will remain at £10,000 subject to annual review, and

■ the Government will continue to explore whether additional changes need to be made in relation to atypical workers and to

improving saving levels among the self-employed.

Master trusts The Pension Schemes Act 2017 sets out a regime for the authorisation and supervision of money purchase master trusts by the Pensions

Regulator. However, it focuses largely on general principles and most of the detail of the new regime was left to regulations.

On 30 November 2017, the DWP issued a consultation paper on draft regulations which are intended to clarify how the new regime will

work, which schemes it will apply to and what such schemes will need to do to achieve (and maintain) authorisation.

In general, where a scheme provides both defined benefit and money purchase benefits, the master trust regime will apply to the money

purchase benefits. There are some exemptions, including where the only money purchase benefits are AVCs or transferred-in benefits

for members who are actively accruing defined benefits. However, there is currently no exemption for most (non-statutory) industry-

wide or not-for-profit schemes.

Consultation on the draft regulations closes on 12 January 2018 and final regulations are expected to come into force in October 2018.

The Regulator plans to publish a code of practice on master trust authorisation in early 2018.

For more information, please click here.

Pensions - Key Legal Issues Guide Winter 2018

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Subject Issue

Pension increases

The High Court case, British Airways plc v Airways Pension Scheme Trustee Limited, in which Eversheds Sutherland acted for the

trustees, looks at the exercise by trustees of a unilateral amendment power to introduce a new provision into scheme rules which

required them to consider annually whether to award a discretionary pension increase in addition to that provided by the rules. BA

complained to the court that both the scheme amendment and subsequent exercise of the trustees’ discretionary power were improper

and should be set aside. The High Court found in favour of the trustees but BA has appealed the decision and the Court of Appeal

hearing is listed for May 2018.

For further information on the BA judgment and appeal, please click here and here.

A number of cases looking at how increase provisions in scheme rules should be interpreted (and whether they allow CPI to be used in

place of RPI) continue to progress through the courts. In the Thales case, the High Court considered what the “nearest alternative”

index to RPI was, concluding that it was revised RPI. In December 2017, the High Court considered whether BT could switch the

measure of inflation used under a section of its scheme from RPI to CPI – the judgment is awaited. Leave to appeal to the Supreme

Court has been granted in the Barnardo’s case, which is due to be heard in June 2018 and looks at the meaning of a “replacement

index”.

There is still no real certainty as to how increase provisions should be interpreted. When considering whether a shift from RPI to CPI (or

another index) is possible, the outcome will depend on the precise wording of the scheme rules.

DB White Paper In February 2017, the Government published a Green Paper that looked at what changes may be made to ensure the long term

sustainability of DB arrangements. Our Speedbrief on the Green Paper is here.

Following on from this, a White Paper is expected to be published by late February 2018. Press reports have suggested that areas of

focus will include consolidation of schemes, benefit simplification and Regulator powers but that any resulting legislation is unlikely to be

enacted before 2020.

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