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DB and hybrid (mixed benefit) scheme return

Additional information and resources to help you prepare for and complete a scheme return for defined benefit (DB) schemes and those offering mixed benefits (hybrid).

See scheme return for further information about completing the scheme return, including the most common queries.

Important

You must complete your scheme return and submit it to us by 31 March 2024.

This year’s scheme return: what’s changed?

A one-part scheme return for all schemes

You will complete the scheme return for your DB or hybrid scheme in one part this year.

An improved format for some questions

In 2023, additional questions for some DB schemes were issued using a separate online form. These will now be available through Exchange along with the new questions about fiduciary managers and investment consultancy providers described below.

You will be asked individual questions or sets of questions on separate pages before submitting your responses. The questions in these sections will have relevant guidance and links alongside them.

New questions and updates this year

New questions requesting information about fiduciary managers and investment consultancy providers

Trustees of relevant trust schemes are legally required to run a competitive tender process when appointing fiduciary managers (or extending an existing appointment) in relation to 20% or more of scheme assets. They are also required to set strategic objectives for their investment consultancy provider in order to receive investment consultancy services. The trustees must review the objectives at least every three years (and promptly after any significant changes to the scheme’s investment principles) to ensure that they remain suitable.

These requirements have been in place since 2019. In October 2022, The Pensions Regulator (TPR) took over responsibility for monitoring compliance with these requirements from the Competition and Markets Authority.

We will ask you for information about your fiduciary managers, including their contact details and when they were appointed to the scheme. We will also ask whether they were appointed using a competitive tender process.

We will also ask you for information about your investment consultancy providers, including their contact details and when they were appointed to the scheme. We will ask when strategic objectives were set for them and when those objectives will be reviewed.

Fiduciary managers

  • Is there a fiduciary manager appointed to the scheme?
  • Fiduciary manager contact details: enter the organisation’s name and address.
  • Fiduciary manager individual contact details: enter the individual’s name, email address and telephone number.
  • Date of appointment to the scheme.
  • Was the fiduciary manager appointed by a competitive tender process?

Read the guidance: Tender for fiduciary management services

Investment consultancy providers

  • Investment consultancy provider contact details: enter the organisation’s name and address.
  • Investment consultancy provider individual contact details: enter the individual’s name, email address and telephone number.
  • Date of appointment to the scheme.
  • Have the trustees of the scheme set strategic objectives for this investment consultant?
  • When were these objectives set?
  • When will these objectives be reviewed?

Read the guidance: Set objectives for your investment consultant

New questions about liquidity and leverage

In April 2023, The Pensions Regulator issued guidance outlining practical steps trustees can take to manage risks when using leveraged liability-driven investment (LDI). This followed the events of September and October 2022, when the Bank of England had to intervene in the gilt market to restore market functioning.

As a trustee, you must ensure you have the right controls and governance around LDI. You need to be confident that you have ways of working with your advisers and managers in place so you can act quickly and effectively, particularly in a crisis. This is particularly true if you have high levels of leverage, meet infrequently as a trustee board or have more infrequent contact with advisers.

This year, we will ask you for details of your liquidity and leverage and the controls you have in place. We will use this to assess whether our guidance is effective and identify areas where stronger controls may be required.

  1. Does the scheme use leveraged LDI?

If you answer ‘Yes’, you will need to complete the rest of the leverage and liquidity section.

Section 1: LDI mandate

For each individual LDI mandate you add, you will be asked the following questions.

  1. Asset manager name
  2. Is the LDI mandate pooled or segregated?
  3. (If you answered ‘Pooled’ to question 3) What is the name of the fund?
  4. What is the net asset value of this LDI mandate as a proportion of the scheme's total assets?
    Answer as a percentage.
  5. What is the yield buffer to zero net asset value (NAV) of this LDI mandate?
    Answer in basis points (BPS).
  6. Does this LDI mandate give the scheme exposure to any other asset classes beyond (nominal or real) interest rates?
  7. Select the exposure beyond (nominal or real) interest rates provided by this mandate:
    Select all that apply: Equity, Credit, Currency, Other.

Section 2: Standalone synthetic equity mandate

  1. Does the scheme use a standalone synthetic equity mandate?

Section 3: Availability of liquidity

  1. What is the breakdown of scheme assets by the frequency on which they regularly trade?
    Give percentages for: Daily, Weekly, Monthly, Quarterly, Less than quarterly.

Section 4: Delivery of liquidity

  1. [If an LDI manager issues a routine request for additional capital] In how many business days are the trustees capable of carrying out the necessary transfers and fulfil the request for capital?
    Select from: 0 to 10 days (and enter the exact number of days), More than 10 days.

Section 5: Efficient governance of transactions

  1. What proportion of the assets (that the trustees envisage selling in response to an LDI manager’s collateral call) have the trustees delegated unlimited authority to a third-party to sell?
    Select one from: All of the assets, Some of the assets, None of the assets.
  2. (If you selected ‘Some’ or ‘None’ to question 12) Do the trustees have a single authorised signatory list or multiple authorised signatory lists?
  3. (If your answer to question 13 was ‘Single’) How many individuals are listed as authorised signatories?
    Select from 1 to 10 (enter the exact number of authorised signatories), More than 10.
  4. (If your answer to question 13 was ‘Multiple’) How many individuals are listed as authorised signatories on the list with the fewest authorised signatories?
  5. When was this list of authorised signatories last reviewed?

Section 6: Systemic liquidity impacts

  1. Do the trustees have a pre-agreed plan of asset sales to fulfil a request for capital from an LDI manager?
  2. (If you answered 'Yes' to question 17) Which asset class is on the first step of the waterfall?
    Select from Bonds, Equity, Property, Diversified growth funds, Absolute return funds, Other or Credit facility.
  3. (If you answered 'No' to question 17) Which is the scheme’s largest holding in a liquid asset class?
    Select from Bonds, Equity, Property, Diversified growth funds, Absolute return funds, Other or Credit facility.
  4. (If your answer to question 18 or 19 was ‘Bonds’, ‘Equity’, ‘Property’, ‘Diversified growth funds’, ‘Absolute return fund’ or ‘Other’) Is the asset class from which the trustees would source the required moneys (from a request from an LDI manager) accessed by a pooled fund?
  5. What are the names of the asset manager and pooled fund? Name of asset manager, Name of pooled fund.
  6. (If your answer to question 18 or 19 was ‘Credit facility’) When was a legal review last carried out on the credit facility?
  7. Does the scheme's LDI manager have discretion to disinvest from the relevant asset class without direct intervention from the trustees?

Read the guidance on using leveraged liability-driven investment

New questions about your pensions dashboard primary contact

Trustees of schemes that are in scope for pensions dashboards need to connect with and supply pensions information to savers through dashboards. 

We will ask for details of the primary contact with regards to pensions dashboard duties. Information will include their name, contact details and whether they are a professional and non-professional trustee.

We will use this information to send the primary contact updates and information about pensions dashboards.

  1. Select the trustee type for the pensions dashboards primary contact: select professional or non-professional.
  2. Pensions dashboard primary contact details: enter the organisation’s name and address.
  3. Pensions dashboard primary contact details: enter the individual’s name and email address.

New questions about your AVC providers

This year, we will ask you for details about the companies which administer defined contribution (DC) pots built up by scheme members making additional voluntary contributions (AVCs).

We will ask you for the names of the companies administering these AVCs (AVC providers) and how many members each AVC provider looks after. You do not need to include your main scheme administrator or any free-standing AVCs (where the contract is established directly between the member and the provider).

  1. Is there an AVC provider for the scheme?
  2. Select AVC provider
  3. (For each AVC provider) How many scheme members have AVC benefits with this AVC provider? (You can provide an estimate rounded to the nearest 100)

Read the help text for AVC providers

Updates to asset breakdown help text

Following analysis of the asset information submitted in the 2023 scheme returns, the help text has been updated to encourage schemes to submit as much of their exposure as possible through the asset breakdown.

We encourage schemes to only submit risk factor stress impacts where there are particularly complex holdings whose exposures cannot be easily reflected in the asset breakdown. You can find more detail on this approach in the ‘Reporting options where the relevant exposures are fully reflected in the asset breakdown’ section.

The asset breakdown help text has also been updated to add further clarity on:

  • how to allocate private debt and inflation-linked bonds
  • the signs (positive or negative) of the various exposures and corresponding risk factor stress impact.

Read the updated asset breakdown help text

When to complete your scheme return

Complete your scheme return and submit it to us by 31 March 2024.

Prepare for your scheme return

Update your scheme contacts using Exchange

Before taking any other action, please log into Exchange and make sure your scheme contact details are up to date. This is so we can make sure the scheme return is sent to the right person along with any further communications.

Make sure you can get the information you need

Take some time to familiarise yourself with your previous scheme return and gather the information you might need. You can generate your previous scheme returns on the Scheme Maintenance section of your scheme return.

We no longer provide an example scheme return. If this is your first scheme return, you can familiarise yourself with the scheme return information requirements and any related guidance.

Find the scheme rules, the latest annual report and accounts and any recent statements of the scheme assets and contributions

Contact any third parties that may hold the required information in good time, as it may take time for them to provide it to you.

If you have any queries about the scheme return, contact us.

Complete your scheme return

Complete and submit your scheme return to us using Exchange, our online service.

If you have a query and need to contact us, we recommend viewing the information and guidance on this website.

You can view the help text for scheme return questions without having to log in to Exchange. You can also select the help icon in Exchange for further guidance on a particular scheme return question.

See further information on how to use Exchange, including how to associate to a registered scheme.

If you still have any queries about the scheme return, contact us. You may prefer to send us an email.

Your legal responsibility

As the trustee or manager of a registrable scheme, you must provide us with a scheme return, unless the scheme has only one member, has wound up or another exemption applies.

If a scheme return hasn’t been completed and submitted by the deadline stated in the scheme return notice, this will be a breach of the Pensions Act 2004 and you risk being fined. Your scheme’s PPF levy calculations may also be impacted by late submissions.